## Geologic Sequestration of Carbon Dioxide Draft Underground Injection Control (UIC) Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Permitting AuthoritiesOffi ce o f Water ( 4606M)

EP A 816- P-1 3 -00 2 www.epa.gov/safewater March 2013Draft UIC Program Class VI Well Recordkeeping, iii March 2 013 Reporting , and Data Management Guidance for Permitting Authorities 

## Disclaimer
The Class VI injection well classification was established by the Federal Requirements U nder the Underground Injection Control (UIC) Program for Carbon Dioxide (CO 2 ) Geologic Sequestration (GS) Wells (75 FR 77230, December 10, 2010) , referred to as the Class VI Rule, which establishes a ne w class of injection well (Class VI)

. The Safe Drinki ng Water Act (SDWA) provisions and the United States Environmental Protection Agency ( EPA ) regulations cited in this document contain legally -binding requirements. In several sections, this guidance document makes suggestions and offers alternatives that go beyond the minimum requirements indicated by the Class VI R ule. This is intended to provide information a nd suggestions that may be helpful for implementation efforts. Such suggestions are prefaced by “may” or “should” and are to be considered advisory. They are not required elements of the Rule. Therefore, this document does not substitute for those provisions or regulations, nor is it a regulation itself, so it does not impose legally-binding requirements on EPA, state s, or the regulated community. The recommendations herein may not be applicable to each and every situation

. EPA and state decision maker s retain the discretion to adopt approaches on a case

- by

- case basis that differ from this guidance where appropriate. Any decisions r egarding a particular facility will be made based on the applic able statutes and regulations. Mention of trade names or commercial products does not constitute endorsement or recommendation for use. EPA is taking an adaptive rulemaki ng approach to regulati ng Class VI injection wells , and the a gency will continue t o evaluate ongoing research and demonstration projects and gather other relevant information as needed to refine the Rule. Consequently, this guidance may change in the future without a formal noti ce and comment period. While EPA has made every effort to ensure the accuracy of the discussion in this document, the obligations of the regulated community are determined by statutes, regulations, or other legally binding requirements. In the event of a conflict between the discussion in this document and any statute or regulation, this document would not be controlling. Note that this document only addresses issues covered by EPA’s authorities under SDWA. Other EPA authorities, such as Clean Air Act ( CAA ) requirements to report carbon dioxide injection activities under the Greenhouse Gas Mandatory Reporting Rule (GHG MRR) are not w ithin the scope of this document.Draft UIC Program Class VI Well Recordkeeping, iv March 2 013 Reporting , and Data Management Guidance for Permitting Authorities 

## Executive Summary

EPA’s Federal Requirements Under the Underground Injection Control (UIC) Program for Carbon Dioxide (CO 2 ) Geologic Sequestration (GS) Wells , codified in the U .S. Code of Federal Regulations [40 CFR 146.81 et seq .], known as the Class VI Rule, establishes a new class of injection well, Class VI , and se ts minimum technical criteria for Class VI injection wells for the purposes of protecting underground sources of drinking water (USDWs). This document is part of a series of guidance documents developed to support owners or operators of Class VI wells and the UIC Program permitting authorities. Under the Class VI Rule, owners or operators of Class VI well s are required to site, constr uct, and operate their wells according to the specific technical criteria that address specific GS activities: site characterization; area of review (AoR) delineation and corrective action; well construction and operation; fin ancial responsibility; testing and monitoring; reporting and recordkeeping; post- injection site care (PISC) and site closure; and emergency and remedial response. Data management, recordkeeping, and reporting are important components of the UIC Program and help ensure that the activities and operations regulated under the program are conducted as planned, are compliant with the regulations and permit conditions, and, ultimately, are sufficiently protective of USDWs. Additionally, EPA is implemen ting an adap tive rulemaking approach to the Class VI Rule, whereby the a gency plans to collect and review data every six years on GS projects to determine whether the appropriate amount and types of information and appropriate documentation are being collected, as wel l as to determine if modifications to the requirements are necessary

. Effective GS data management significantly impacts the effectiveness of this effort

. This guidance closely referenc es other UIC Program Class VI well guidance documents for technical detail s. In particul ar, the information provided in this guidance document com plements the information given in the UIC Class VI Implementation Manual for State Directors and the UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators. This guidance document has been developed to provide information to and describe possible approaches for UIC Program Directors to address various aspects of reporting, recordkeeping, and data management associated with GS projects operating under the Class VI Rule. Additionally, the Class VI Rule, at 40 CFR 146.91(e), requires owners or operators of Class VI wells to report all submittals to EPA in an approved electronic format. As such , this guidance document also describes EPA’s electronic reporting and data management system

. 1 Followin g the introductory section, which describes the purpose and organization of this guidance document, Section 2 describes reporting, recordkeeping, and data management associated with UIC Program Directors’ activities that take place during the different pha ses of a

1 At the time this draft document was published, the central data system for Class VI data was under development. To avoid publishing inco mplete information, this draft contains a placeholder for the description of GS data management through the use of the central data system.Draft UIC Program Class VI Well Recordkeeping, v March 2 013 Reporting , and Data Management Guidance for Permitting Authorities GS project’s life cycle. Section 3 describes the centralized, integrated electronic reporting system maintained by EPA, and presents the overall electronic data submission procedures and data management operations for UIC Program Directors

.Draft UIC Program Class VI Well Recordkeeping, vi March 2 013 Reporting , and Data Management Guidance for Permitting Authorities 

## Table of Contents

Disclaimer ..................................................................................................................................... iii Executive Summary ..................................................................................................................... iv Table of C ontents ......................................................................................................................... vi List of Tables .............................................................................................................................. viii List of Figures ............................................................................................................................. viii Acronyms and Abbreviations ..................................................................................................... ix Definitions ...................................................................................................................................... x 1 Introduction ........................................................................................................................... 1 1.1 Importance of Effective Class VI Reporting and Data Management ............................... 1 1.2 Purpose of Guidance ........................................................................................................ 2 1.3 Relationship to Other EPA Guidance............................................................................... 3 1.4 Organization of this Document ........................................................................................ 4 2 Reporting and Recordkeeping Associated with Permitting Authority Responsibilities 5 2.1 Pre -Injection Phase: Prior to Construction ....................................................................... 8 2.1.1 Class VI Well Permit Application ............................................................................ 8 2.1.2 Site Characterization ............................................................................................... 11 2.1.3 AoR and Corrective Action .................................................................................... 12 2.1.4 Financial Responsibility

.......................................................................................... 14 2.1.5 Injection Well Construction .................................................................................... 15 2.1.6 Proposed Activities and Project Plans .................................................................... 16 2.1.7 Injection Depth Waivers ......................................................................................... 19 2.2 Pre

- Injection Phase: Prior to Injection ........................................................................... 22 2.2.1 Site Characterization ............................................................................................... 22 2.2.2 Final AoR and Corrective Action Status ................................................................ 23 2.2.3 Injection Well Construction and Testing ................................................................ 24 2.2.4 Final Project Plans .................................................................................................. 26 2.3 Injection Phase ............................................................................................................... 27 2.3.1 In jection Well Operation

......................................................................................... 27 2.3.2 Testing and Monitoring........................................................................................... 29 2.3.3 Reevaluation of AoR and Phased Corrective Action .............................................. 30 2.3.4 Project Plan Updates ............................................................................................... 32 2.3.5 Financial Responsibility Updates and Notifications ............................................... 34 2.3.6 Emergency and Remedial Response ....................................................................... 35 2.4 Post-Injection Phase ....................................................................................................... 36 2.4.1 Injection Well Plugging .......................................................................................... 36 2.4.2 PISC and Site Closure ............................................................................................. 38 2.4.3 Emergency and Remedial Response ....................................................................... 40 2.5 UIC Program Director Program Reporting to EPA ....................................................... 41Draft UIC Program Class VI Well Recordkeeping, vii March 2 013 Reporting , and Data Management Guidance for Permitting Authorities 2.6 Recordkeeping by the UIC Program Director ................................................................ 43 3 GS Data Submission and Management ............................................................................. 44 Appendix A. Draft Class VI Oversight and Compliance Data Elements Matrix ............... A-1

## List of Tables
Table 2 -1. Activities and submittals required under the Class VI Rule for the phases of a GS project....

......................................................................................................................................... 7 Table A -1. Class VI Rule oversi ght and compliance data elements matrix (DRAFT). .............. A-1



## List of Figures Figure 2

- 1. The phases of a GS project’s life cycle with associated activities required by the Class VI Rule and the sections of this guidance document that add ress each activity.. .................. 6

Draft UIC Program Class VI Well Recordkeeping, viii March 2 013 Reporting , and Data Management Guidance for Permitting AuthoritiesDraft UIC Program Class VI Well Recordkeeping, ix March 2 013 Reporting , and Data Management Guidance for Permitting Authorities 

## Acronyms and Abbreviations

AoR Area of review CAA Clean Air Act CFR Code of Federal Regulations CO 2 Carbon dioxide EPA Environmental Protection Agency GAO Government Accountability Office GHG MRR Greenhouse Gas Mandatory Reporting Rule GS Geologic sequestration MIT Mechanical integrity test OMB Office of Management and Budget PAM Program Activity Measure PDF Portable document format PISC Post- injection site care PWSS Public Water System Supervision QA/QC Quality assurance/quality control RCRA Resource Conservation and Recovery Act SDWA Safe Drinking Water Act SNC Significant noncompliance TDS Total dissolved solids UIC Underground Injection Control USDW Underground source of drinking waterDraft UIC Program Class VI Well Recordkeeping, x March 2 013 Reporting , and Data Management Guidance for Permitting Authorities 

## Definitions Key to definition sources: 1: Class VI Rule Preamble 2: 40 CFR 144.3 3: 40 CFR 146.81(d) 4: This definition was drafted for the purposes of this document 5 : E PA’s UIC website ( http://water.epa.gov/type/groundwater/uic/glossary.cfm ) 6: 40 CFR 144.6(f) and 144.80(f) Annulus means the space between the well casing and the wall of the borehole; the space between concentric strings of casing; the space between casing and tubing. 1 Aquifer exemption refers to a special exemption that removes an aquifer or part of an aquifer from SDWA prote ction when certain requirements [at 40 CFR 146.4] are met to demonstrate that the exempted aquifer does not currently serve as source of drinking water and has no real potential to be used as drinking water source in the future. One basis for demonstrating that an aquifer will not be used in the future is to show that it is mineral producing or capable of mineral production. 4 Area of review (AoR) means th e region surrounding the geologic sequestration project where USDWs may be endangered by the injection activity. The area of review is delineated using computational modeling that accounts for the physical and chemical properties of all phases of the injected carbon dioxide stream and displaced fluids, and is based on available site characterization, monitoring, and operational data as set forth in 40 CFR 146.84. 3
Automatic shut
- off device refers to a valve coupled with a control device that closes the valve when a pre- determined set pressure or flow value is exceeded. Shut

- off devices in injection wells can automatically shut down injection activities when operating parameters unacceptably diverge from permitted values

. 4 Carbon dioxide plume means t he extent underground, in three dimensions, of an injected carbon dioxide stream. 3
Carbon dioxide stream means c arbon dioxide that has been captured from an emission source (e.g., a power plant), plus incidental associated substances derived from the source materials and the capture process, and any substances added to the stream to enable or improve the injection process. This subpart [subpart H of 40 CFR 146] does not apply to any carbon dioxide stream that meets the definition of a hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA) under 40 CFR part 261.3. 3 Casing means pipe material p laced inside a drilled hole to prevent the hole from collapsing. The two types of casing in most injection wells are ( 1) surface casing, the outer

- most casing that extends from the surface to the base of the lowermost USDW and (2) long string casing, which extends from the surface to or through the injection zone. 1Draft UIC Program Class VI Well Recordkeeping, xi March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Cement means material used to support and seal the well casing to the rock formations exposed in the borehole. Cement also protects the casing from corrosion and prevents movement of injectate up the borehole. The composition of the cement may vary based on the well type and purpose; cement may contain latex, mineral blends, or epoxy. 1
Class I well means a tec hnologically sophisticated well that injects wastes into deep, isolated rock formations b elow the lowermost USDW. Class I wells may inject hazardous waste, non

hazardous industrial waste, or municipal wastewater. 5
Class II well s means wells that inject brines and other fluids associated with oil and gas production, or storage of hydrocarbons. Class II well types include salt water disposal wells, enhanced oil recovery w ells, enhanced gas recovery wells, and hydrocarbon storage wells. 5
Class V well means a well designed and constructed for injection, but not included in the definitions of Class I, II, III, IV , or VI wells. Clas s V wells inject non -hazardous fluids int o or above a USDW and are typically shallow, on- site disposal systems; however, this class also includes some deeper injection operations. There are approximately 20 subtypes of Class V wells. 5
Class VI wells means wells that are not experimental in nature that are used for GS of carbon dioxide beneath the lowermost formation containing a USDW; or, wells used for GS of carbon dioxide that have been granted a waiver of the injection depth requirements pursuant to requirements at 40 CFR 146.95; or, wells used for GS of carbon dioxide that have received an expansion to the areal extent of an existin g Class II enhanced oil recovery or enhanced gas recovery aquifer exemption pursuant to 40 CFR 146.4 and 144.7(d). 6 Computational code refers to a series of interrelated mathematical equations solved by computer to represent the behavior of a complex system. For the purposes of GS, computational models represent, at a minimum, the flow and transport of multiple fluids and components in varying phases through porous media. Computational codes offer the ability to predict fluid flow in the subsurface using sc ientifically accepted mathematical approximations and theory. The use of computational codes is necessary because the mathematical formulations describing fluid flow are complicated and in many cases, non

- linear. Several codes have been specifically develo ped or tailored for injection activities similar to GS, and can be used for this purpose. 4 Computational model means a mathematical representation of the injection project and relevant features, including injection wells, site geology, and fluids present. For a GS project, site specific geologic information is used as input to a computational code, creating a computationa l model that provides predictions of subsurface conditions, fluid flow, and carbon dioxide plume and pressure front movement at that site. The computational model comprises all model input and predictions (i.e., output). 4 Confining zone means a geologic f ormation, group of formations, or part of a formation stratigraphically overlying the injection zone(s) that acts as barrier to fluid movement. For Class wells operating under an injection depth waiver, confining zone means a geologic formation, VIDraft UIC Program Class VI Well Recordkeeping, xii March 2 013 Reporting , and Data Management Guidance for Permitting Authorities group of formations, or part of a formation stratigraphically overlying and underlying the injection zone(s). 3
Corrective action means t he use of UIC Program Director -approved methods to ensure that wells within the AoR do not serve as conduits for the movement of fluids into USDWs. 3
Corrosive means having the ability to wear away a material by chemical action. Carbon dioxide mixed with water forms carbonic acid, which can corrode well materials. 1
Enhanced gas recovery means the process of injecting a gas (i.e., carbon dioxide) into a gasbearing formation to displace available gas to allow it to be produced. 4 Enhanced oil recovery means the process of injecting carbon dioxide into an oil reservoir to thin (decrease the viscosity) of extractable oil, which is then available for recovery. 4 Enhanced recovery means either enhanced oil recovery or enhanced gas recovery. 4
Fluid means any material or substance which flows or moves whether in a semisolid, liquid, sludge, gas or other form or state. 2 Formation or geological formation means a layer of rock that is made up of a certain type of rock or a combination of types. 1 Geologic sequestration (GS) means t he long-term containment of a gaseous, liquid, or supercritical carbon dioxide stream in subsurface geologic formations. This term does not apply to carbon dioxide capture or transport. 3 Geologic sequestration project means an injection well or wells used to emplace a carbon dioxide stream beneath the lowermost formation containing a USDW; or, wells used for GS of carbon dioxide that have been granted a waiver of the injection depth requirements pursuant to requirements at 40 CFR 146.95; or, wells used for GS of carbon dioxide that have received an expansion to the areal extent of an existing Class I I enhanced oil recovery or enhanced gas recovery aquife r exemption pursuant to 40 CFR 146.4 and 144.7(d). It includes the subsurface three -dimensional extent of the carbon dioxide plume, associated area of elevated pressure, and displaced fluids, as well a s the surface ar ea above that delineated region. 3 Injectate means t he fluids injected. For the purposes of the Class VI Rule , this is also known as the carbon dioxi de stream. 1 Injection depth waivers refer to the provisions at 40 CFR 146.95 that allow owne rs or operators to seek a waiver from the Class VI injection depth requirements for GS to allow injection into non-USDW forma tions while ensuring that USDWs are protected from endangerment. 4 Injection zone means a geologic formation, group of formations, or part of a formation that is of sufficient areal extent, thickness, porosity, and permeability to receive carbon dioxide through a well or wells associated with a GS project. 3Draft UIC Program Class VI Well Recordkeeping, xiii March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Mechanical integrity means the absen ce of significant leakage within the injection tubing, casing, or packer (known as internal mechanical integrity), or outside of the casing (known as external mechanical integrity)

. 1 Mechanical integrity test (MIT) refers to a test performed on a well to c onfirm that a well maintains internal and external mechanical integrity. MITs are a means of measuring the adequacy of the construction of an injection well and a way to detect problems within the well system. 1
Model means a representation or simulation of a phenomenon or process that is difficult to observe directly or that occurs over long time frames. Models that support GS can predict the flow of carbon dioxide within the subsurface, accounting for the properties and fluid content of the subsurface form ations and the effects of injection parameters

. 1 Owner or operator means the owner or operator of any facility or activity subject to regulation under the UIC program. 2
Packer means a mechanical device that seals the outside of the tubing to the inside of the long string casing, isolating an annular space. 1
Phased corrective action refers to a provision of the Class VI Rule [40 CFR 146.84(b)(2)(iv)] afforded t o Class VI i njection well owners or operators to defer some identified corrective action needed within the AoR , but farther away from the injection well, until after injection has commenced, but prior to carbon dioxide plume and pressure front movement into that particular area. 4
Post
- injection site care (PISC) means a ppropriate monitoring and other actions (including corrective action) needed following cessation of injection to ensure that USDWs are not endangered, as required under 40 CFR 146.93. 3
Pressure front means the zone of elevated pressure that is created by the injection of carbon dioxide into the subsurface. For GS projects, the pressure front of a carbon dioxide plume refers to the zone where there is a pressure differential sufficient to cause the movement of injected fluids or formation fluids into a USDW. 3 Primacy (primary enforcement r esponsibility) means t he authority to implement the UIC Program. To receive primacy, a state, territory, or tribe must demonstrate to EPA that its UIC program is at least as stringent as the federal standards; the state, territory, or tribal UIC requiremen ts may be more stringent than the federal requirements. (For Class II, states must demonstrate that their programs are effective in preventing pollution of USDWs.) EPA may grant primacy for all or part of the UIC program, e.g., for certain classes of injec tion wells. 5
Site closure means the specific point or time, as determined by the UIC Program Director following the requirements under 40 CFR 146.93, at which the owner or operator of a GS site (Class VI injection well) is released from PISC responsibiliti es. 3Draft UIC Program Class VI Well Recordkeeping, xiv March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Total dissolved solids (TDS) refers t o the measurement, usually in mg/L, for the amount of all inorganic and organic substances suspended in liquid as molecules, ions, or granules. For injection operations, TDS typically refers to the saline (i.e., salt) content of water

- saturated underground formations. 1
Transmissive fault or fracture means a fault or fracture that has sufficient permeability and vertical extent to allow fluids to move between formations. 3 Tubing refers to a small

- diameter pipe installed inside the casing of a well. Tubing conducts injected fluids from the wellhead at the surface to the injection zone and protects the long string casing of a well from corrosion or damage by the injected fluids. 5 Underground Injection Control (UIC ) Program refers to t he program EPA , or an approved state, is authorized to implement under the SDWA that is responsible for regulating the underground injection of fluids by wells injection. This includes setting the federal minimum requirements for construction, operation, permitting, and closure of underground injection wells. 4 Underground Injection Control (UIC) Program Director refers to the chief administrative officer of any state or tribal agency or EPA Region that has been delegated to operate an approved UIC program. 5 Underground source of drinking water (USDW) means a n aquifer or portion of an aquifer that supplies any public water system or that contains a sufficient quantity of ground water to supply a public water system, and currently supplies drinking water for human consumption, or that contains fewer than 10,000 mg/L TDS and is not an exempted aquifer. 1
Well bore refers to the hole that remains throughout a geologic (rock) formation after a well is drilled. 4
Workover refers to any maintenance activity performed on a well that involves ceasing injection or production and removing the wellhead. 4Draft UIC Program Class VI Well Recordkeeping, 1 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities 

## 1 Introduction To ensure the protection of underground sources of drinking water (USDWs), the United States Environmenta l Protection Agency (EPA) established minimum federal requirements for the proper management of carbon dioxide injection and storage under the authority of Part C of the Safe Dri nking Water Act (SDWA) in December 2010. The Federal Requirements U nder the Un derground Injec tion Control (UIC) Program for Carbon Dioxide (CO 2 ) Geologic Sequestr ation (GS) Wells , found at 75 FR 77230 and hereafter referred to as the Class VI Rule, requires well owners or operators to collect, generate, and report specific information needed to inform permitting decisions and decisions related to siting, constructing, operating, monitoring, and closing a Class VI well [40 CFR 146.81 et seq. ]. The Class VI Rule defines a new class of injection well s , Class VI, along with technical criteria that tailor the UIC Program’s existing regulatory framework to address the unique nature of carbo n dioxide injection for geologic sequestration ( GS ) . These technical criteria a ddress different components of a GS project : site characterization; area of r eview (AoR) delineation and corrective action; well construction and operation; financial responsibility; testing and monitoring; reporting and recordkeeping; post- injection site care (PISC) and site closure ; and emergency and remedial response

. Figure 2- 1 presents a general sequence of these specific activities within a GS project workflow. Under the Class VI Rule, UIC Program Directors have ove rsight responsibilit ies related to permitting, i mplementation, and compliance under the UIC P rogram. For UIC P rograms administered by EPA, the UIC Program Director is the EPA Regional Administrator or his/her de signee ; for UIC Programs in primacy s tates, tribes, or territories, the UIC Program Director is the state agency responsible for permitting, impleme ntation, and compliance of the state, tribal , or territorial UIC P rogram . The overs ight responsibilities of the UIC Program Director are to ensure that owners or operators of Class VI wells properly site, operate, monitor, and close their wells in a manner that protects USDWs. These responsibilities include reviewing permit applications and writing permits, authorizing injection, reviewing testing a nd monitoring results during the injection and post -injection phases, addressing compliance issues, and approving site closure. Reporting, recordkeeping, and data management are an integral part of documenting and demonstrating effective oversight by the U IC Program and safe deployment of underground injection operations and protection of USDWs.

1.1 Impor tance of Effective Class VI Reporting and Data Management The Class VI Rule , at 40 CFR 146.91(e), requires owners or operators of Class VI wells to submit al l reports in an electronic format approved by EPA. Given the nature of Class VI well operations and the more comprehensive requirements of the Class VI Rule compared to those for other UIC well classes, the Interagency Task Force on Carbon Capture and Stor age recommended the use of “ a national data system that would promote regulatory certainty, efficiency, and accountability, while allowing transparency of all geologic sequestration relatedDraft UIC Program Class VI Well Recordkeeping, 2 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities information .” 2 Therefore, all of the data required under the Class VI Rule must be s ubmitted to and retain ed in an EPA data system, regardless of whether the well is in a state that has primacy. The UIC Program Directors will use this data system to access and manage the GS data submitted by owners or operators of Class VI wells. Additionally, E PA is implementing an adaptive rulemaking approach to the Class VI Rule, whereby EPA p lans to collect and review data every six years on GS projects to determine whether the appropriate amount and types of information and document ation are being collected, and to determine if modifications to the requirements are necessary. Successful GS data management through the use of an electronic data system helps facilitate and significantly imp rove the effectiveness of GS effort s. Furtherm ore, i nformation on the performance of Class VI wells that is managed by a central , integrated data system will help EPA evaluate the success of the Class VI Program by allowing tracking, evaluating, and reporting on program performance. The information wi ll also enable EPA to respond to information requests and perform analyses for Congress, the public, and other interested parties. This information also enables the UIC Program Director to substantiate and provide the rationale behind decisions related to compliance or a determination of USDW endangerment. Pursuant to the requirements under 40 CFR 144.8, an owner or operator’ s failure to comply with site -specific permit conditions, complete construction as specified in the UIC permit , provide compliance schedules or monitoring reports, or submit complete reports is considered to be an instance of noncompliance and a violation of the permit under Section 1423 of SDWA . Similarly, an owner or operator’s performance of any action that causes USDW endangerment du ring the life of the GS project would also be considered noncompliance and a violation of the permit. EPA may use information submitted as evidence of an imminent and substantial endangerment of a USDW, which may require remedial action under Section 1431 of SDWA

.

1.2 Purpose of Gui dance As part of a series of guidance documents that provide information on Class VI well operations that are prot ective of USDWs and comply with the Class VI Rule, the purpose of this guidance is to provide:

• A comprehen sive descr iption of reporting and recordkeeping recommendations associated with permitting authority responsibilities for each phase of a GS operation ( see Figure 2-1 ).

• Information on how the reporting, recordkeeping, and data management activities will ensure USDW protection, inform the adaptive approach, support compliance determinations and national program oversight, and meet intera gency data needs

.

2 Interagency Task Force on Carbon Capture and Storage . 2010. Report of the Interagency Task Force on Carbon Capture and Storage , p. C

- 8. Available on the Internet at: http://www.epa.gov/climatechange/downloads/CCS

- Task

Force

- Report

- 2010.pdf

.Draft UIC Program Class VI Well Recordkeeping, 3 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities • A comprehensive description of EPA ’s central data system use d for the purpose of reporting, recordkeeping, and data management by permitting authorities. This guidance does not provide information or recommendations on how UIC Program Directors can make deci sions that are protective of USDWs. Information on the UIC Program Director’s evaluation and considerations for decision-making related to issuing permits, reviewing testing and monitoring results, evaluating AoR reevaluations and plan updates, and authori zing site closure can be found in the UIC Program Class VI Implementation Manual for State Directors

. EPA re commends that UIC Program Directors utilize both this reporting guidance and the UIC Program Class VI Implementation Manual for State Directors to g ain a comprehensive understanding of their responsibilities. 1.3 Relati onship to Other EPA Guidance This document is one of a series of guidance documents intended to provide information and possible approaches to UIC Program Directors for addressing various aspects of reporting, recordkeeping, and data management associated with GS projects operating under the Class VI Rule. As this guidance document closely references the UIC Progr am Class VI Implementation Manual for State Directors, it also complements the UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators . Cross-linkages between guidance documents are noted in the text where appropriate. These additional UIC Program Class VI guidance documents can be fou nd, when available, on EPA’s website at http://water.epa.gov/type/groundwater/uic/class6/gsguidedoc.cfm :

• UIC Program Class VI Financial Responsibility Guidance

.

• UIC Program Class VI Implementation Manual for State Directors.

• UIC Program Class VI Primacy Manual for State Directors.

• UIC Program Class VI Well Area of Review Evaluation and Corrective Action Guidance.

• UIC Program Class VI Well Construction Guidance.

• UIC Program Class VI Well Injection Depth Waivers Guidance.

• UIC Program Class VI Well Project Plan Development Guidance.

• UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators.

• UIC Program Class VI Well Site Characterization Guidance

.

• UIC Program Class VI Well Testing and Monitoring Guid ance.

• UIC Program Guidance on Class VI Well Plugging, Post-Injection Site Care, and Site Closure.Draft UIC Program Class VI Well Recordkeeping, 4 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities • UIC Program Guidance on Transitioning Class II Wells to Class VI Well s. 1.4 Organization of t his Document Following this introduction, the remainder of this document is organized as follows:

• Section 2 , Reporting and Recordkeeping Associated with Permitting Authority Responsibilities , presents the specific information to be documented (e.g., compliance, enforcement, violation, etc.) by UIC Program Directors under the Class VI R ule with additional information on reporting timeframes and record retention requirements.

• Section 3 , GS Data Submission and Management, describes the centralize d, integrated electronic reporting system maintained at EPA and presents the overall data submission procedures and data management operations for UIC Program permitting authorities. It also addresses all aspects of interagency data management operations e mployed within the repor ting system

. 3 Table A -1 in Appendix A summarizes the information provided in Section 2 in a table of oversight and compliance data elements tha t EPA recommends UIC Program Directors document during the lifetime of a GS project.

3 At the time this draft document was published, the central data system for Class VI data wa s under development. To avoid publishing incomplete information, this draft contains a placeholder for the description of GS data management through the use of the central data system.Draft UIC Program Class VI Well Recordkeeping, 5 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities 

## 2 Reporting and Recordkeeping Associated with Permitting Authority Responsibilities
The Class VI Rule sets forth minimum f ederal r equirements to protect USDWs from endangerment during underground injection of carbon dioxide for the purpose of GS. These requirements are tailored to address different phases of a GS project: pre- injection , injection , and post- injection ( Figure 2-1 , Table 2-1 ) . During the lifecycle of a GS project, permitting authorities are responsible for ensuring that:

• Each Class VI proje ct is sited and planned such that USDWs are protected, considering site - and project-specific information in the pre-injection phase.

• Class VI wells are operating as planned, in compliance with the regulations and as verified by testing and monitoring, and in a way that is protective of USDWs during the injection phase.

• PISC is conducted until there is no risk of endangerment to USDWs resulting from Class VI well activities

. To achieve these goals, UIC Program Director s will receive and evaluate information submitted by owners or operators, pe rform required notifications, and provide critical information about their oversight responsibilities to EPA . The final decision regarding the appropriateness and acceptability of all owner or operator submissions rests with the UIC Program Director. This section describes EPA’s recommendations regarding the information to be documented and reported by the UIC Program Director to support compliance and oversight decisions , GS data management, and the adaptive rulemaking process. This information includes:

• The UIC Program Director’s decisions with regard to the issuance of permits, oversight, and compliance.

• Responses to owner or operator submissions.

• Information necessary for national program oversight and the adaptive rulemaking approach

.Draft UIC Program Class VI Well Recordkeeping, 6 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities

Figure 2-1 . The phases of a GS project ’s life cycle with associated activities required by the Class VI Rule and the sections of this guidance document that ad dress each activity.Draft UIC Program Class VI Well Recordkeeping, 7 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities T able 2-1 . Activities and submittals require d under the Class VI Rule for the phases of a GS project.
GS Project Phase Activities/Submittals and Relevant Sections of this Document Pre

- injection (before construction) • Class VI w ell p ermit a pplication: Section 2.1.1

• Site c haracterization d ata and p roposed p re -o perational f ormation t esting p rogram: Section 2.1.2

• AoR d e lineation and c orrective a ction , including the p roposed AoR and Corrective Action Plan: Section 2.1.3

• Fin ancial responsibility demonstration: Section 2.1.4

• Pr oposed i njection w ell c onstruction p rocedures, s chematics, d rawings, and s timulation p rogram: Section 2.1.5

• Pr oposed a ctivities and p roject p lans: Section 2.1.6
o Pr oposed o perating d ata and p rocedure s
o Proposed Testing and Monitoring Plan
o Proposed Injection Well Plugging Plan
o Proposed PISC and Site Closure Plan and , at the UIC Program Director’s discretion, a demonstration of an a lternative PISC t imeframe
o Proposed Emergency and Remedial Response Plan

• Documentation for wells transitioning from Class II to Class VI:

Section 2.1.1.1

• In je ct ion d epth w aiver a pplication r eport: Section 2.1.7
Pre

- injection (before operation) • Updated site characterization data and pre

- operational fo rmation testing program results: Section 2.2.1

• Fin al AoR documentation and status of corrective action: Section 2.2.2

• In jection w ell c onstruction and t esting d ocumentatio n: Section 2.2.3

• Fin al project p lan s : Section 2.2.4 Injection • Injection w ell o peration d ata: Section 2.3.1

• Te sting and m onitoring r esults: Section 2.3.2

• Doc umentation of AoR r eevaluation and p hased c orrective a ction: Section 2.3.3

• Pr oject plan and alternative PISC timef rame demonstration updates: Section 2.3.4

• Fin ancial r esponsibility u pdates and n otifications: Section 2.3.5

• Doc umentation of any e mergency events and associated r emedial r esponse activities : Section 2.3.6
Post

- i njection • Injection w ell p lugging r eport : Section 2.4.1

• PI SC m onitoring r esults, n on -e ndangerment d emonstration, and s ite c losure n otifications and report : Section 2.4.2

• Doc umentation of any emergency events and associated remedial response activities : Section 2.4.3Draft UIC Program Class VI Well Recordkeeping, 8 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities 2.1 Pre
- Injection Phase : Prior to Construction Under the Class VI Rule, UIC Program Directors will receive submittals prior to the construction of a new Class VI well or the conversion of an existing Class I, Cl ass II, or Class V experimental technology well to a Class VI well during the pre-injection phase as required at 40 C FR 146.82(a) through ( d)

. Based on this information, the UIC Program Director will determine whether to issue a Class VI permit

. This section describes the UIC Program Dir ector’s recommended reporting and data management activities that occur prior to injection well construction or conversion ( see Table 2-1). 2.1.1 Class VI Well Permit Application The p ermit ap plication for a Class VI well is compose d of submittals documenting the activities conducted and/or proposed by owners or operators as required under 40 CFR 146.82(a). These activities are related to site characterization, AoR del ineation and corrective action, injection well construction, and demonstration of financial responsibility. Additional submittals include proposed project plans and descriptions of proposed activities as presented in Table 2-1

. T he UIC Program Director must evaluate permit applications submitted by owners or operators to determine whether the application is complete and that the proposed project will not endanger USDW s. T he permit application and evaluation process is an iterative one, which EPA expects to begin with “pre

- application” communication between the UIC Program Director and the owner or operator of a proposed GS project. A detailed checklist of all required Class VI permit applicatio n material s is given in the UIC Program Class VI Implementation Manual for State Directors , along with descriptions of how the UIC Program Director will evaluate this information. Reporting and recordkeeping requirements specific to owners or operators during the permit application process are discussed in the UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators. In addition, UIC Program Director s may use their discretion to request any additional information needed to support their evaluation and ensure that the proposed Class VI project is protective of USDWs [40 CFR 146.82(a)(21 )]. For the purpose of ensuring complete and consistent compliance and oversight evaluations and supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC Program Directors document the following information associated with their evaluations of Class VI permit applications :

• The da te that the permit application was received

.

• The name and contact information of the applicant and other relevant project staff.

• The project name and duration.

• A d etermination of whether the permit application is complete or a description of identified deficiencies . (Under 40 CFR 124.3(c), each application for an EPA -issued permit submitted for a new UIC injection well should be reviewed for completeness by the EPA Regional Administrator within 30 days of its receipt.)Draft UIC Program Class VI Well Recordkeeping, 9 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities • A determination of whether the information provided in the permit appli cation is accurate, in compliance with the requirements of the Class VI Rule , and demonstrates that the proposed operation will not endanger any USDWs, or a determination that additional information is needed. Examples of deficiencies may include, but are not limited to:

o Need for additional site characterization information (see Section 2.1.2).

o Incomplete maps o r cross sections of the AoR and/or tabulation of all wells that penetrate the injection or confining zone(s) (e.g., the map omits other injection wells; see Section 2.1.3).

o Insufficient demonstration of financial responsibility (see Section 2.1.4 ).

o Need for additional information on injection well construction (see Section 2.1.5 ).

o Incomplete proposed project plans or injection well operation data (see Section 2.1.6).

o Insufficient demonstration of an alternative PISC timeframe , if one is proposed (see Section 2.1.6).

o Incomple te list of contacts for s tates, tribes, and t erritories within the AoR.

• A copy of any requests for additional information or related communications with the owner or operator, including:

o The date of the request.

o The n ames and affiliations of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information. Following review of the permit application, the UIC Program Director will dr aft the Class VI permit, which authorizes the owner or operator to construct the well and provide s preliminary operating and monitoring requirements . The Class VI Rule , at 40 CFR 146.82(b), requires UIC Program Directors to notify s tates, tribes, and territories within the AoR based on the information provided by the owner or operator. In addition, the UIC Program Director will also notify the public according to the public notification requirements in 40 CFR 124.10, and retain administrative records pu rsuant to 40 CFR 124.9 for draft permits when EPA is the permitting authority. 2.1.1.1 Re -P ermitting of Injection Wells Owners or operators of wells injecting carbon dioxide for enhanced recovery must apply for a Class VI permit if a determination is made that the primary purpose of the project is long

- termDraft UIC Program Class VI Well Recordkeeping, 10 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities storage of carbon dioxide and that there is an increased risk to US DWs compared to Class II operations [40 CFR 144.19].Owners or operators of existing Class V experimen tal technology wells that seek to use their wells to inject carbon dioxide for long- term storage must also apply for a Class VI permit. Re

- permitting of injection wells is described in detail in both the UIC Program Class VI Implementation Manual for State Directors and the UIC Program Guidance on Transitioning Class II Wells to Class VI Well s. For the purposes of re -permitting, the well owner or operator mu st submit a Class VI permit applica tion and comply with all Class VI requirements under 40 CFR 146. However, c ertain elements of the well construction may be grandfathered . Pursuant to 40 CFR 146.81 (c) , an owner or operator may choose to demonstrate that a converted well was engineered and constructed to meet the requirements at 40 CFR 146.86 (a) and will ensure protection of USDWs, in lieu of meeting the requirements at 40 CFR 146.86(b) and 146.87(a). EPA recommends that t he UIC Program Director document the following information for oversight and compliance purposes resulting from their evaluations of these demonstrations:

• A d etermi nation whether the demonstration is sufficient to approve the grandfathering of certain components of the injection wel l and a description of these components.

• A description of identified deficiencies or information needs with regard to the demonstration.

• A copy of any requests for additional information or related communications with the owner or operator, including:

o The date o f the request.

o The n ames and affiliations of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information. In addition, owners or operator s converting Class II wells that inject into exempted aquifers may requ est , before or concurrent with the Class VI permit application, to expan d the areal extent of a previously approved aquifer exemption [40 CFR 144.7(d)]. The UIC Program Guidance on Transitioning Class II Wells to Class VI Well s describes the UIC Program Director’s evaluation of such a request. No designation of an expansion to the areal extent of a Class II enhanced recovery aquifer exemption for GS will be final unless approved by the EPA Regional Administrator as a revision to the applicable f ederal UIC Program under 40 CFR 147 or as a su bstantial revision of an approved state UIC P rogram under 40 CFR 145.32. For compliance and oversight purposes, EPA recommends that the UIC Program Director document the following information related to an aquifer expansion request:

• A d etermin ation of whether the submitted information for the aquifer expansion request is complete , or a description of any identified deficiencies in the submitted information.Draft UIC Program Class VI Well Recordkeeping, 11 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities • A copy of any requests for additional information or related communications with the owner or operator, including:

o The date of the request.

o The n ames and affiliations of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Correspondences with the EPA Regional Administrator about the proposed aquifer exemption expansion, t he d ecision of the EPA Regional Administrator , and the date of the decision

.

• Any additional compliance or oversight information. 2.1.2 S ite Characterization The Class VI Rule , at 40 CFR 146.82 (a) , requir es owners or operators of Class VI wells to submit certain site characterization information prior to the issuance of a permit for the construction or conversion of a Class VI well

. This site characterization information includes an assessment of the geologic, geomechanical, and hydrogeologic characteristics of the proposed storage site and overlying formations; a tabulation of all wells within the AoR; information on USDWs; baseline geochemical data; and a proposed program for pre - operational formatio n testing. Detailed information on performing site characterization activities is given in the UIC Program Class VI Well Site Characterization Guidance, and a description of the specific submittals made by owners or operators is given in the UIC Program Cl ass VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators. EPA rec ommends that, for the purpose of ensuring complete and consistent compliance and oversight evaluations , as well as supporting the adaptive rulemaking approa ch for the Class VI Rule, UIC Program Directors document the following information resulting from their evaluat ions of the site characterization information in the permit application :

• Document ation that all of the materials required under 40 CFR 146.82(a)(2) through (6) are present and are of acceptable quality

.

• A description of any identified deficiencies or concerns. Examples of such deficiencies may include, but are not limited to :

o Missing information required under 40 CFR 146.82(a)(2) through (6).

o Poor data quality or insufficient documentation of quality assurance/quality control (QA/QC) procedures

.
o Poorly constructed or labeled maps or cross sections

.
o Unsuitable data collection methods for the samples or site.Draft UIC Program Class VI Well Recordkeeping, 12 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities o Insufficient documentation of test procedures or results.

o Inconsistencies among data types or concerns over ambiguous interpretation s of geologic data

.
o Concerns regarding the suitability of the site ( e.g., integrity of the confining zone, capacity of the injection zone, seismicity, formation geochemistry ).

• Documentation that any technical concerns regarding the site characterization information have been resolved.

• Determination that the site is suitable for GS (pending the results of the formation testing program) or, if technical co ncerns cannot be resolved, a decision that the site is unsuitable for GS.

• A copy of any requests for additional information or related communications with the owner or operator, including:

o The date of the request.

o The n ames and affiliations of parties invo lved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information. 2.1.3 AoR and Corrective Action The Class VI Rule , at 40 CFR 146.84, requires owners or opera tors of Class VI wells to prepare, maintain, and comply with a plan to delineate the AoR for a proposed GS proje ct , periodically reevaluate the delineation, and perform corrective action on all deficient wells in the AoR

. Detailed information on performing AoR modeling and delineation, corrective action, and periodic AoR reevaluations is given in the UIC Program Class VI Well Area of Review Evaluation and Corrective Action Guidance. Submissions made by owners or operators to fulfill reporting requirements for AoR delineation and corrective action , along with record retention requirements, are described in the UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators

. Prior to the authorization of Class VI wel l construction , t he UI C Program Director ’s responsibilities include reviewing the proposed AoR and Corrective Action Plan, the initial AoR delineation , and the identification of corrective action needs

. During his or her review, the UIC Program Director wi ll evaluate the AoR and Corrective Action Plan to ensure that it is consistent with the available site -specific data and proposed operational information , that it includes all relevant artificial penetrations, and that the AoR reevaluation schedule and the conditions that would warrant a reevaluation of the AoR are appropriately identified. Furthermore, the UIC Program Director will ensure that the AoR delineation is conducted in a way that is compliant with the Class VI Rule requirements. D etailed recommen dations and considerations forDraft UIC Program Class VI Well Recordkeeping, 13 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities conducting this evaluation are given in the UIC Program Class VI Implementation Manual for State Dir ectors

. For the purpos e of ensuring complete and consistent compliance and oversight evaluations and supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC Progra m Directors document the following information resulting from their evaluations :

• For the AoR and Corr ective Action Plan (in addition to the considerations applicable to all project plans, which are addressed in Section 2.1.6):

o A deter mination of whether th e list of wells requiring corrective action is complete , based on the UIC Program Director’s knowledge of pertinent well databases and preliminary information on the AoR (i.e. , an assessment of whether the owner or operator consulted all applicable information sources).

o Approv al of the schedule for AoR reevaluations.

o If applicable, the approval decision for phased corrective action, including s pecific well identification information and the proposed schedule for conducting corrective action

.
o Any i dentified site -specific and/or operational triggers for AoR reevaluations prior to the next scheduled reevaluation

.

• For the AoR delineation:

o A description of any deficiencies identified in the AoR delineation. Examples of such deficiencies may include, but are not l imited to:

 Inconsistencies identified between the information used in modeling and site - and operation- specific data

.

 Use of a computational code that does not appropriate ly account for the physical and chemical characteristics of the injectate

.

 F ailing to account for other significant influences on subsurface pressures and fluid movements, such as other injection activities.

o The name of the c omputational code the owner or operator used for the AoR delineation

.
o The s imulation period used in modeling for final AoR delineation as submitted by the owner or operator.

o A d ecision on the appropriateness and compliance of the modeling approach with the C lass VI Rule

.
o Information on contractors used by the owner or operator, if applicable and provided.Draft UIC Program Class VI Well Recordkeeping, 14 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities o Information on contractors used by the UIC Program Director , if applicable.

• A copy of any requests for additional information or related communications with the owner or operator, including:

o The date of the request.

o The n ames and affiliations of parties involved in th e communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information. 2.1.4 Financial Responsibility The Class VI Rule , at 40 CFR 146.85, requires owners or operators of Cla ss VI wells to demonstrate and maintain financial responsibility for corrective action, injection well plugging, PISC, site closure, and emergency and remedial response. Detailed information on these requirements and the associated reporting and recordkeeping by owners or operators is provided in the UIC Program Class VI Financial Responsibility Guidance and the UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators

. The qualif ying financial responsibility instrument(s) must be approved by the UIC Program Director as a part of the initial financial responsibility demonstration. The UIC Program Director must consider and approve the financial responsibility demonstration for all phases and may disapprove a fin ancial instrument if it is not sufficient to fulfill obligations as established in the initial cost estimate. Detailed recommendations for conducting this evaluation and a summary of the applicable considerations are given in the UIC Program Class VI Well Implementation Manual for State Directors. For the purpos e of complete and consistent compliance and oversight evaluations and supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC Program Direc tors document the following information resulting from their evaluations of initial financial responsibility demonstrations:

• A deter mination whether the proposed f inancial responsibility instrument(s) are from the list of qualifying instruments

.

• A description of any deficiencies identified in the financial responsibility demonstration. Examples of such deficiencies may include, but are not limited to:

o Instruments based on performance are combined with payment instruments.

o Third -party providers do not meet minimum requirements

.
o A s tandby trust fund is not established for select third -party instruments.

o Minimum requirements are not met for self insurance, if applicable.Draft UIC Program Class VI Well Recordkeeping, 15 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities o The length of the pay-in period for trust funds and escrow accounts is insufficient.

• A determination of whether the qualifying instrument(s) are sufficient to cover required activity costs , are sufficient to address endangerment of USDWs, and comprise protective conditions of coverage.

• A determination of whether the cost estimate is complete and compliant with the requirements.

• A copy of any requests for additional information or related communications with the owner or operator, including:

o The date of the request.

o The n ames and affiliations of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information. 2.1.5 Injection Well Construction The Class VI Rule , at 40 CFR 146.86, requires owners or operators to construct wells that will prevent m ovement of fluids into unauthorized zones, permit use of appropriate testing devices and workover tools, and allow monitoring of the annulus between the tubing and casing. The Rule also provides specific requirements regarding the casing, cement, tubing, and packer , intended to prevent such fluid movement. Details on injection well construction requirements for Class VI wells are provided in the UIC Program Class VI Well Construction Guidance , and reporting and recordkeeping requirements for owners or operators are discussed in the UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators. Prior to the construction of the injection well, t he owner or operator must submit proposed construction schematics and procedures [40 CFR 146.82(a)(11) and (12) ]. Additionally, the owner or operator must submit a plan for stimulation procedure s, if stimulation is to be performed [40 CFR 146.82(a)(9)]. The UIC Program Director’s responsibilities include reviewing construct ion plans and procedures for completeness and to ensure that the goals of preventing fluid movement, allowing testing and workover equipment, allowing monitoring of the annulus, and ensuring mechanical integrity for the life of the well are met

. The UIC Pr ogram Class VI Implementation Manual for State Directors can be consult ed for further information on the UIC Program Director ’s evaluations. For the purpos e of ensuring complete and consistent compliance and oversight evaluations and supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC Progra m Directors document the following information resulting from their evaluations of proposed injection well construction submittals:Draft UIC Program Class VI Well Recordkeeping, 16 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities • A d etermination of whether the proposed injectio n well construction procedures, schematics , and drawings sufficiently address all requirements related to the casing, cement, tubing, and packer and would prevent USDW endangerment.

• A d etermination of approval of the proposed stimulation program.

• A description of any identified deficiencies or concerns. Examples of such deficiencies may include, but are not limited to:

o Poorly constructed or labeled schematics and drawings

.
o Insufficient information to approve casing size, material, and strength

.
o Insufficient information on the volume of cement, cementing procedures, or the c ompatibility of cement materials with the injectate and formation fluids

.

• A copy of any requests for additional information or related communications with the owner or operator, including:

o The date of the request.

o The n ames and affiliations of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information. 2.1.6 Propose d A ctivities and Project Plans The Class VI Rule requires owners or operators to submit a set of proposed project plans as part of the per mit application [40 CFR 146.82(a)(13), (15), (16), (17), and (19)]. These plans are:

• An AoR and Cor rective Action Plan that meets the requirements of 40 CFR 146.84.

• A Testing and Monitoring Plan that meets the requirements of 40 CFR 146.90.

• An Injection Well Plugging Plan that meets the requirements of 40 CFR 146.92(b).

• A PISC and Site Closure Plan that meets the requirem ents of 40 CFR 146.93(a).

• An Emergency and Remedial Response Plan that meets the requirements of 40 CFR 146.94(a). Section 2.1.3 describes some specific considerations for the AoR and Corrective Action Plan. Details on the development of all of the project plans are provided in the UIC Program Class VI Well Project Pla n Devel opment Guidance. It is the UIC Program Director’s responsibility to review and approve the proposed project plans, including communicating with the owner or operator regarding any additional information necessary to support and evaluate the plans.Draft UIC Program Class VI Well Recordkeeping, 17 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities For the purpose of ensuring complete and consistent compliance and oversight evaluations and supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC Progra m Directors document the following information resulting from thei r evaluations of the proposed project plans:

• A d etermination of whether the proposed plans are complete and in compliance with the requirements of the Class VI Rule as cited above

.

• Any deficiencies in the plan s based on the UIC Program Director’s review

. Examples of such deficiencies may include, but are not limited to:

o The AoR a nd Corrective Action Plan does not contain a sufficient description of the method for delineating the AoR, the AoR reevaluation schedule, the conditions that would warrant a reeval uati on or model calibration, or how corrective action will be conducted.

o The Testing and Monitoring Plan does not consider si te access for future activities or does not sufficiently describe procedures for injectate monitoring , mechanical integrity testing (MIT) , corrosion monitoring, plume and pressure front monitoring, monitoring geochemical changes in the subsurface, or, if required by the UIC Program Director, surface air and/or soil gas monitoring

.
o The Injection Well Plugging Plan does not include a description of appropriate tests or measures to determine bottom- hole reservoir pressure or ensure external mechanical integrity ; the type and number of plugs; the placement of each plug; the type, grade, and quantity of material to be used in plugging; or the method of plug placement.

o The PISC and Site Closure Plan does not include sufficient information on the differential between pre -injection and predicted post-injection pressures, the predicted position of the plume and pressure front, or post- injection monitoring locations, methods, and frequency.

o The Emergency and Remedial Response Plan does not contain a complete list of potentially impacted environmental resources and risk scenarios, or identified response actions and personnel and equipment to implement the response actions.

o Any plan does not adequately address site

- specific considerations identified elsewhere in the permit application.

• The result of the UIC Program Director’s evaluation and the date of the determina tion.

• A copy of any requests for additional information or related communications with the owner or operator, including:

o The date of the request.

o The n ames and affiliations of parties involved in the communication

.Draft UIC Program Class VI Well Recordkeeping, 18 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information. Pursuant to 40 CFR 146.93( c) , the owner or operator may include in the PISC and Site Closure Plan a proposed alternative PISC timeframe (i.e., a timeframe other than 50 years) . The UIC Program Guidance on Class VI Well Plugging, Post-Injection Site Care, and Site Closure provides m ore information on the requirements for demonstrating that an alternati ve PISC timeframe is appropriate and the UIC Program Class VI Implementation Manual for State Directors includes considerations for the UIC Program Director’s evaluation. In eva luating an alternative PISC timeframe demonstration, the UIC Program Director must determine if the demonstration meets the criteria under 40 CFR 146.93(c)(2). EPA recommends that UIC Program Directors document the following information resulting from their evaluations:

• The proposed alternative PISC timeframe (i.e., the number of years).

• A determination of whether the PISC timeframe demonstration is complete , and that all documentation required under 40 CFR 146.93(c)(1) is present and acceptable

.

• A description of any identified deficiencies or concerns, and whether the information submitted meets the criteria under 40 CFR 146.93(c)(2).

• The re sult and date of the UIC Program Director’s determination.

• A copy of any requests for additional information or related communications with the owner or operator, including:

o The date of the request.

o The n ames and affiliations of parties involved in the com munication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information. In addition to the proposed GS project plan s, owners or operators must also submit proposed operating parameters and procedures for the Class VI project, and the steps necessary to conduct the injection operation [40 CFR 146.82(a)(9) and (10)]. This submission is described in the UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators , and the UIC Program Class VI Implementation Manual describes considerations for the UIC Program Director’s Review. EPA re commends that UIC Program Directors document the following information resulting from their evaluatio ns of the proposed operating data:Draft UIC Program Class VI Well Recordkeeping, 19 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities • A determination of whether the proposed operating data is complete pursuant to the requirements at 40 CFR 146.82(a)(7).

• A description of any identified deficiencies or concerns (e.g. the proposed injection pressure or ant icipated carbon dioxide volumes seem inconsistent with submitted site characterization data ).

• A copy of any requests for additional information or related communications with the owner or operator, including:

o The date of the request.

o The names and affiliat ions of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information. 2.1.7 Injection Depth Waiver s Concurrently with the permit application process, owners or operators may seek a waiver of the Class VI Rule requirement to inject beneath the lowermost USDW [40 CFR 146.95]. Waiver applica tions must be approved by the EPA Regional Administrator [40 CFR 146.95(d)(2)] to ensure that interstate boundary and water resource issues are addressed and to contribute to national consistency in waiver issuance. The owner or operator must submit a waiver application report at the time of the initial permit application that includes the information specified in 40 CFR 146.95(a)(1) through (7). While the waiver application report is submitted concurrently with the Class VI permit application , the report is not considered part of the permit application. The UIC Program Class VI Injection Depth Waivers Guidance provides recommendations for completing and evaluating the waiver application report, and the UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators describes the reporting requirements associated with the waiver application process for owners or operators. The UI C Program Director is responsible for verifying that the materials in the waiver application report are complete as required by 40 CFR 146.9 5(a) and evaluating them for consistency and technical soundness. The UIC Program Director must also consult with the Public Water System Supervision (PWSS) Directors of the states and tribes in the AoR and provide public noti ce of the waiver application [40 CFR 146.95(b)(2) and 146.95 (c)]. After receipt of public input and , if an injection depth waiver is recommended, the UIC Program Director must provide all information received to the EPA Regional Administrator [40 CFR 146.95(d)] . If requested by the EPA Regional Administrator , the UIC Program Director must provide additional information to support his or her determination including providing additional public notice [40 CFR 146.95(d)(1)].Draft UIC Program Class VI Well Recordkeeping, 20 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities T he UIC Program Class VI Implementation Manual for State Directors includes considerations for the UIC Program Director’s evaluation of the waiver application report, as well as more information on the consultation and public notification process. EPA has also developed a paper titled Additional Considerations for UIC Pr ogram Directors: Interstate Coordination Requirements for the Class VI Injection Well Permitting Process , which provides more information on interstate coordination. For the purpos e of ensuring complete and consistent compliance and oversight evaluations and supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC Progra m Directors document the following information related to the waiver application process:

• A d etermin ation of whether the information submitted in the waive r application report is complete

.

• A description of any identified deficiencies or concerns with the waiver application report . Examples of such deficiencies may include, but are not limited to, a missing, insufficient, or incorrect:

o Demonstration of the integrity of the upper and lower confining units and the suitabi lity of the injection zone(s)

.
o Demonstration of the lack of transmissive faults and fractures.

o Documentation of any artificial penetrations into or through the injection zone(s).

o Demonstration of storage capacity, accounting for availability of alternative injection sites

.
o Documentation of community needs, demands, and supply from dri nking water resources and documentation of planned needs and potential/future use of USDWs and non- USDWs

.
o Documen tation of planned or permitted water, hydrocarbon, or mineral resource exploitation

.
o Proposed plan for securing alternative resources or treating USDWs in the event of c ontamination related to Class VI activit ies

.
o Site characterization information (see Sec tion 2.1.2 for compliance and oversight determinations related to site characterization)

.

• The U IC Program Director’s determination that the site is suitable for an injection depth waiver (pending results of the formation testing program) or , if technical concerns cannot be resolved, a decision that the site is unsuitable for an injection depth waiver.

• Documentation of the consultation with the applicable PWSS Direct or(s) , including:

o Date, n ames , and af filiations of parties involved in the communication(s)

.Draft UIC Program Class VI Well Recordkeeping, 21 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities o Copy of the letter sent to the PWSS Directors (see the UIC Program Class VI Implementation Manual for State Directors for a template)

.
o Record of other materials se nt to the PWSS Directors

.
o W ritten waiver

- related information submitted by the PWSS Director(s) to the UIC Progra m Director

.

• Information related to public noti ce of the waiver application per 40 CFR 146.95(c), including:

o A copy of the public notice.

o The date of the notification.

o The method of publication.

o A record of any public comments received and the responses from the UIC Program Director.

• Documentation of the EPA Regional Administrator’s evaluation, such as:

o A copy of the materials submitted to the E PA Regional Administrator and the date of submission.

o Copies of any materials sent to the EPA Regional Administrator in response to a request for additional information and the date(s) of submission.

o Information related to additional public notice, if required by the EPA Regional Administrator.

o A copy of the EPA Regional Administrator’s concurrence with issuance of the waiver and the date the determination was received.

o The date of waiver issuance, if applicable.

• A copy of, or links to, information regarding the injection depth waiver that is posted on EPA’s website, pursuant to 40 CFR 146.95(e).

• A copy of any requests for additional information or related communications with the owner or operator, including:

o The date of the request.

o The names and affiliat ions of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information.Draft UIC Program Class VI Well Recordkeeping, 22 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities 2.2 Pre
- Injection Phase : Prior to Injection Following the construction o f a Class VI well, th e UIC Program Director must review additional information submitted by owners or operators pursuant to 40 CFR 146.82(c) before issuing a final permit authoriz ing injection. This information is primarily related to final site characteri zation and well construction data based on the results of pre - injection testing. This section describes the UIC Program Director’s recommended reporting and data management responsibilities , related to these activities (see Table 2-1). In addition, following the decision to authorize injection, the UIC Program Director will retain administrative records pursuant to 40 CFR 124.18 for final permits. 2.2.1 Site C haracterization During drilling and construction of the well, the owner or operator must execute the formation testing plan to collect the information required at 40 CFR 146.87 and update the preliminary information submitted with the initial permit application [40 CFR 14 6.82(c)(2) and (4)]. These formation testing activities are described in the UIC Program Class VI Well Site Characte rization Guidance and the related reporting and recordkeeping activities performed by owners or operators are described in the UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators. Prior to a uthorizing injection, the UIC Program Director will review the well log, core, and fluid sampling results and compare the information to the previously submitted site characterization data. He or she will evaluate whether any updates to the site characterization information or changes to the site geologic conceptual model are sufficient to raise concerns about the integrity of the confining zone, alter th e storage capacity estimation, or necessitate changes in planned operational parameters. D etailed considerations for the UIC Program Director ’s evaluation are given the UIC Program Class VI Implementation Manual for State Directors. For the purpose of ensu ring complete and consistent compliance and oversight evaluations and supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC Progra m Directors document the following information resulting from their evaluations:

• The dat e of receipt for all submittals.

• A description of any deficiencies or concerns. Examples of such deficiencies may include, but are not limited to:

o Insufficiently documented procedures or results.

o Any concerns over the suitability of the site for GS based on final site characterization data.

• A copy of any requests for additional information or related communications with the owner or operator, including:

o The date of the request.Draft UIC Program Class VI Well Recordkeeping, 23 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities o The n ames and affiliations of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information. 2.2.2 Final AoR and Corrective Action Status Prior to granting approval for injection, the UIC Program Director conducts an evaluation to ensure that results of formation testing and logging (as well as other updates to the site characterization data and the proposed operational data) are incorporated in to the final delineation of the AoR [40 CFR 146.82(c)(1)]. Additionally, the UIC Program Director evaluates the status of corrective action on wells in the AoR [40 CFR 146.82(c)(6)]. Detailed information on how the UIC Program Director conducts the evaluation and a summary of all considerations for this evaluation are given in the UIC Program Class VI Implementation Manual for State Directo rs
. The UIC P rogram Director should document receipt of the final AoR delineation and the corrective action status, noting whether the material is complete or if additional information is nee ded. F or the purpose of ensuring complete and consistent compliance and oversight evaluations and supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommen ds that UIC Program Directors document the following information resulting from their evaluations:

• The date of receipt for all final submittals.

• For the AoR and Corrective Action Plan, if updated (in addition to the considerations applicable to all project plans, which are addressed in Section 2.2.4):

o If app licable, the approval decision for phased corrective action, including s pecific well identification information for the proposed schedule for conducting corrective action

.
o The final a pproved schedule for AoR reevaluations.

o The final i dentified site -specific and/or operational triggers for AoR reevaluations prior to the next scheduled reevaluation

.

• For the f inal AoR delineation:

o A d etermination whether the final delineation is complete , complies with the requirements at 40 CFR 146.84(c) , and adequately describes the area that will be impacted by carbon dioxide injection at the anticipated volumes and rates.

o A description of any deficiencies identified in delineation, such as inconsistenc ies between the information used in modeling and final site - and operation- specific data based on the formation testing program results.Draft UIC Program Class VI Well Recordkeeping, 24 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities o The name of the computational code used for the delineation as submitted by the owner or operator.

o The s imulation perio d used for final AoR delineation modeling as submitted by the owner or operator.

o I nformation on contractors used by the owner or operator, if applicable and provided.

o Information on contractors used by the UIC Program Director , if applicable.

• For c orrective action activities :

o Documentation of any notifications that corrective action has been conducted, including:

 Date of the notification

.

 A list of wells that received corrective action, the date the corrective action was performed (if known), and the type of corrective action (e.g., plugging, remedial cementing).

o A determination of whether the list of wells that received corrective action is complete (compared to the list submitted with the permit application ) and the corrective action is acceptable.

o A d etermination of whether all testing and remedial cementing records for wells that received corrective action are complete

.

• A copy of any requests for additional information or related communications with the owner or operator, including:

o The d a te of the request.

o The n ames and affiliations of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any other compliance or oversight information. 2.2.3 Injection Well Construction and Testing P rior to receiving authorization to inject , the owner or operator must submit final construction procedures demonstrat ing that the well was constructed in compliance with the requirements at 40 CFR 146.86 [40 CFR 146.82(c)(5)]. The owner or operato r must also submit a demonstration of mechanical integrity [40 CFR 146.82(c)(8)]. Details on injection well construction requirements for Class VI wells are included in the UIC Program Class VI Well ConstructionDraft UIC Program Class VI Well Recordkeeping, 25 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Guidance. The UIC Program Class VI Implementation Manual for State Directors can be consulte d for further information on the UIC Program Director ’s evaluation of this information

. The UIC P rogram Director should document receipt of the materials and whether the material is complete or additional information is needed for the purpose of ensuring complete and consistent compliance and oversight evaluations. EPA recommends that UIC Program Directors document following information resulting from their evaluations of injection w ell construction submittals:

• The date of receipt for all submittals.

• A d etermination of whether the final injection well construction procedures are consistent with the approved plan and stimulation program, if applicable.

• If applicable, a determination th at any revisions to the well construction are documented in as

- built specifications and are acceptable to ensure non

- endangerment of USDWs.

• Documentation regarding the design, approval, and installation of required safety devices and pressure monitoring ga uges.

• A description of any identified deficiencies or concerns

. Examples of such deficiencies may include, but are not limited to, insufficient information on:

o Deviation checks on the well and logs showing the actual trajectory and depths of the well

.
o Logs of the drilling and cementing of the well

.
o Cement setting times

.
o Results of pressure tests on casings.

o Descriptions of any deviations from the approved construction procedures.

o Completion records ( e.g., perforation type and location, stimulation methods u sed)

.

• A r ecord of any remedial work required

.

• The date that well construction began.

• The d ate of well completion

.

• The date(s) of any testing performed on the well.

• A record of a pproval of construction results, including pressure tests and cement bond logs

.

• A copy of any requests for additional information or related communications with the owner or operator, including:Draft UIC Program Class VI Well Recordkeeping, 26 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities o The date of the request.

o The n ames and affiliations of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information. 2.2.4 Final Project Plan s The Class VI Rule, at 40 CFR 146.82 (c)(9) , requires owners or operators to submit any updates to the proposed project plans listed in Secti on 2.1.6 that are necessary based on new information collected during logging and testing of the well and the formations. It is the UIC Program Director’s responsi bility to review the final project plans. Based on his or her review, the UIC Program Director approves the final project plans or communicates with the owner or operator regarding any additional information necessary to support and evaluate the materials

. The UIC Program Class VI Implementation Manual for State Directors can be consulte d for further information on the UIC Program Director ’s evaluations. For the purpos e of ensuring complete and consistent compliance and oversight evaluations and supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC Progra m Directors document the following information resulting from their evaluations of the final proposed project plans:

• The date of receipt for all submittals.

• A d etermination of whether the updated materials are complete and comply with the requirements of the Class VI Rule (see Section 2.1.6 for C lass VI Rule citations specific to each project plan) and the date of the determination.

• Any d eficiencies in the materials based on the UIC Program Director’s evaluation (e.g., plan does not incorporate or adequately address new site

- specific information identified during formation logging and testing ).

• A c opy of any requests for additional information or related communications with the owner or operator, including:

o The date of the request.

o The n ames and affiliations of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information.Draft UIC Program Class VI Well Recordkeeping, 27 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities 2.3 Injection Phase During the injection phase, the owner or operator will generate and submit monitoring , testing, and operational data at varying intervals, including semi -annually and prior to or following specific events (e.g., 30 -day notifications and 24-hour emergency notifications). The owner or operator will also submit periodic AoR reevaluations and updates to the required project plans, as well as updates to the financial responsibility instruments and cost estimate s . The permitting authority is responsible for evalu ating these submittals and documenting necessary compliance and oversight information. Additionally, the permitting authority will need to document data generated as a result of inspections or enforcement actions. This information may include :

• Information on inspections, including the date on which an inspection was conducted, the inspector, and the result of the inspection.

• Documentation of compliance or enforcement actions conducted (e.g., notice of violation, administrative order, judicial action issued ).

• Any response and/or remedial action that resulted from inspection and enforcement actions. Where permit modifications are needed pursuant to 40 CFR 144.39(a)(5) or 144.41(h) (e.g., based on AoR reevaluations, amendments to any of the GS project plans, annual updates to financial responsibility information , review s of testing and monitoring data), information associated with the permit modification process will need to be recorded. This may include milestone data related to writing a new permit or inform ation about the public noti fication process. This section describes the UIC Program Director’s recommended reporting and data management responsibilities associated with activities that occur in the injection phase, including documentation of the oversigh t and compliance information associated with the activities described above. 2.3.1 Injection Well Operation The Class VI Rule , at 40 CFR 146.88, sets requirements for the operation of Class VI wells. These r e quirements include limitations on injection pressure, prohibition of injection between the outermost casing and well bore, monitoring of the annulus pressure, maintenance of mechanical integrity, installation of monitoring equipment and safety devices, and implementation of certain procedures in case of a loss of mechanical integrity. Documentation of the design, approval, and installation of safety devices and pressure monitoring gauges will have been provided as part of the well design and construction submittals (see Section 2.2.3 ). Record ed injection pressures will be submitted with the required testing and monitoring reports, as described in Section 2.3.2

. Details on operating requirements for Class VI wells are included in the UIC Program Class VI Well Construction Guidance , and reporting and recordkeeping information for owners orDraft UIC Program Class VI Well Recordkeeping, 28 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities operators is included in the UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators. It is the UIC Program Director ’s responsibility to review documented operating information, such as information provided in the semi -annual reports, to ensure t hat injection well operation is proceeding as planned , the owner or operator is in compliance with the Class VI permit, and the well is not endangering USDWs. The UIC Program Class VI Implementation Manual for State Directors provides considerations for the UIC Program Director’s evaluation

. For the purpos e of ensuring complete and consistent compliance and oversight evaluations and supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC Progra m Directors document the following information related to injection well operation :

• The d ate of receipt for all submittals.

• The dates and results of any pressure tests or other mechanical integrity tests ( MITs ).

• A copy of any requests for additional information or related communic ations with the owner or operator, including:

o The date of the request.

o The n ames and affiliations of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information. Determining compliance with the injection pressure requirement will require information from two sources . First , the site characterization submissions will need to be reviewed to determine the fracture pressure of the injection zo ne ; this should be reflected in the injection pressure limits stipulated in the Class VI permit . Second, the regular monitoring reports will need to be reviewed to ensure that the pressure did not exceed the 90 percent threshold (or a lower injection press ure set as a permit condition) . Similar review s will be necessary for annulus pressure information

. EPA recommends that the UIC Program Director document the following:

• The date of any excursions over the injection pressure limit set in the Class VI permit

.

• Any actions taken as a result of pressure excursions over the permitted range. Finally , the UIC Program Director must respond to any notification of a loss of mechanical integrity. If a loss of mechanical integrity or the triggering of a safety valve occurs , EPA recommends that the UIC Program Director document the following (see also Section 2.3.6 for additional information related to emergency reporting) :

• The time and date of the incident.Draft UIC Program Class VI Well Recordkeeping, 29 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities • How the UIC Program Director learned of the incident (e.g., documentation of received notifications) and the time and date the incident was reported to the UIC Program Director.

• Documentation of conversations between the UIC Program Director and the owner or operator regarding necessary responses to the event, including approvals, if applicable.

• Actions taken by the owner or operator, including times and dates of these actions

.

• Any remedial work done.

• The schedule for returni ng the well to service or for plugging the well.

• The dates , types, and results of tests to demonstrate that mechanical integrity has been restored.

• The date of approval to return the well to service (and copies of any written communications regarding this approval) and the date that injection resumed. If well stimulation is to be performed over the course of the project, EPA recommends that the UIC Program Director document the following information:

• The date that the notification of the planned stimulation was received and the date of the plan n ed stimulation operation

.

• The date of the stimulation operation.

• The results of the stimulation, including any reports submitted by the owner or operator. 2.3.2 Testing and Monitoring The Class VI Rule, at 40 CFR 146.90, requires owners or operators to follow an approved Testing and Monitoring Plan to ensure that the Class VI project is operating in a manner that protect s USDWs. Testing and monitoring requirements, at a minimum, include : analysis of the chemical and physical characteristics of the carbon dioxide stream, MITs, corrosion monitoring, monitoring the position of the carbon dioxide plume and pressure front, monitoring of geochemical changes in the subsurface, surface air and/o r soil gas monitoring (required at the discretion of the UIC Program Director), and any additional tests necessary to ensure USDW protection. More information on the required testing and monitoring for Class VI projects can be found in the UIC Program Class VI Well Testing and Monitoring Guidance

. The Class VI Rule, at 40 CFR 146.91, requires owners or operators to submit testing and monitorin g data in semi -annual reports, within 30 days of conducting testing, and/or in 24-hour notifications, depending on the type of information. Reporting and recor dkeeping requirements associated with testing and monitoring are discussed in the UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators. Detailed information the UIC Program Director’s evaluation of this i nformation can be found in the UIC Program Class VI Implementation Manual for State Directors.Draft UIC Program Class VI Well Recordkeeping, 30 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities For the purpose of ensuring complete and consistent compliance and oversight evaluations and supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC Progra m Directors document the following information resulting from their evaluations of testing and monitoring results:

• The date of receipt and type of submission (semi-annual report, 30- day notification/report, or 24-hour notification).

• A determination of whether the submitted documentation is complete and complies with the requirements under 40 CFR 146.90 and 146.91.

• A description of any deficiencies or concerns. These deficiencies may include missing information or insufficiently documented procedures or results of the specific testing and monitoring activities listed under 40 CFR 146.90.

• A determination of whether the testing and monitoring results indicate exce edance of a permitted parameter, carbon dioxide excursion, or USDW en dangerment; whether an AoR reevaluation is warranted; and whether monitoring results for the injected carbon dioxide plume and/or the associated pressure front differ significantly from model predictions.

• A copy of any requests for additional information or related communications with the owner or operator, including:

o The date of the request.

o The n ames and affiliations of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information. 2.3.3 Reevaluation of AoR and Phased Corrective Action During the injection and post -injection phases, owners or operators of permitted Class VI wells are re quired to reevaluate the AoR delineation on a regular basis, at a frequency determined in the AoR and Corrective Action Plan (at least once every five years) [40 CFR 146.84(e)]. The Class VI Rule requires owners or operators to revise the AoR and Corrective Action Plan if a revision of the AoR delineation is necessary following a reevaluation [40 CFR 146.84(e)(4)]. It is important to note that a change in the AoR and/or the AoR and Corrective Action Plan after the permit is issued may constitute a modification of the UIC permit. Additionally, if the UIC Program Direc tor has authorized a phased corrective action approach for a given Class VI project, the owner or operator will submit document ation of completed corrective action activities

. More inform ation on periodic AoR reevaluations, revisions to the AoR and Corrective Action Plan , and phased corrective action is given in the UIC Program Class VI Well Area of ReviewDraft UIC Program Class VI Well Recordkeeping, 31 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Evaluation and Corrective Action Guidance. Reporting and recordkeeping information specific to owners or operators is described in the UIC Program Class VI Well Recordkeeping, Reporti ng, and Data Management Guidance for Owners or Operators. Detailed information on the UIC Program Director ’s evaluation and a summary of considerations for this evaluation are given in the UIC Program Cl ass VI Implementation Manual for State Directors. For the purpos e of ensuring complete and consistent compliance and oversight evaluations and supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC Progra m Directors docu ment the following information resulting from their evaluations:

• For AoR reevaluation s:

o The date of the reevaluation and the submission.

o The reason for reeval uation (i.e., planned or triggered).

o A determination of whether the AoR and Corrective Action Plan must be amended.

o A determination of whether additional corrective action is needed, including (if applicable) a l ist of wells needing corrective action that are not identified in the approved AoR and Corrective Action Plan.

• For the revised AoR delineation:

o A determination of whether the revised delineation is complete and complies with the requirements under 40 CFR 146.84(c).

o A description of any deficiencies identified in the delineation, such as inconsistencies identified between the informati on used in modeling and updated site - and operation- specific data based on the formation testing program results.

o A d ecision on the appropriateness of the modeling approach and its comp liance with the Class VI Rule

.
o Information on contractors used by the owner or operator, if applicable and provided.

o Information on contractors used by the UIC Program Director , if applicable.

• If an amendment to the AoR and Corrective Action Plan is needed (in addition to the considerations applicable to all project plans, wh ich are addressed in Section 2.3.4):

o Document ation of changes to the size or shape of the AoR.

o Documentation of any necessary changes to the phased corrective acti on schedule, if applicable.Draft UIC Program Class VI Well Recordkeeping, 32 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities o W hether the list of wells requiring corrective action is complete , based on the UIC Program Director’s knowledge of pertinent well databases (i.e., an assessment of whether the owner or operator consulted all applicable information sources).

• For p hased c orrective action activities :

o Documentation of any n otification s that corrective action has been conducted, including:

 Date of the notification

.

 A list of wells that received corrective action during the current phase, the date that corrective action was performed (if available), and the corrective action completed (e.g., plugging, remedial cementing).

o Whether corrective action has been completed for all wells in the current phase (compared to the wells identified in the AoR and Corrective Action Plan).

o A d etermination whether all testing and remedial cementing records for wells that received corrective action submitted are complete

.

• A copy of any requests for additional information or related communications with the owner or operator, including:

o The date of the request.

o The n ames and affiliations of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information. 2.3.4 Project Plan Updates Owners or operators must periodically review the AoR and Corrective Action, Testing and Monitoring, and Emergency and Remedial Response Plans and update them if necessary based on operating or monitoring data or the most recent AoR reevaluation [40 CFR 146.84(e)(4), 146.90(j), and 146. 94(d), respectively]. These reviews occur after AoR reevaluations, based on testing and monitoring data, and/or fol lowing changes to the facility, as well as when required by the UIC Program Director. The Class VI Rule does not require formal periodic reviews and amendment s of the Injection Well Plugging Plan or the PISC and Site Closure Plan during the injection phase; however, EPA recommends that owners or operators and the UIC Program Director communicate regarding potential changes to these plans. More information on completing and documenting plan updates can be found in the UIC Program Class VI Well Projec t Plan Development Guidance and the UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators

.Draft UIC Program Class VI Well Recordkeeping, 33 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities The UIC Program Director’s responsibilities include reviewing amendments to the project plans. Based on his or her review, the UIC Program Director approves the amended project plans or communicates with the owner or operator regarding any additional information necessary to support and evaluate the plan updates. Amended plans must be incorporated into the permit and are subj ect to the permit modification requirements under 40 CFR 144.39 and 144.41, depending on the extent of the updates. The UIC Program Class VI Implementation Manual for State Directo rs includes more information on plan amendments and permit modifications, as well as additional considerations for UIC Program Directors. For the purpos e of ensuring complete and consistent compliance and oversight evaluations and supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC Progra m Di rectors document the following information resulting from their evaluations:

• The submi ssion date of an amended plan or demonstration that no amendment is necessary.

• The reason for the review of the plan(s) (e.g., AoR reevaluation, facility change, UIC Prog ram Director requirement), including the date of the associated AoR reevaluation, if applicable.

• A determination of whether the amended plan(s) are complete and comply with the requirements of the Class VI Rule.

• A summary of significant changes to any of the plans, such as:

o Additional corrective action needs.

o Revision of the alternative PISC timeframe.

o Additional testing and /or monitoring.

o New emergency and remedial response procedures.

• The result of the review of the revised plan(s) and the date of the de termination.

• Documentation of whether a permit modification is required, and whether the modification will be issued under 40 CFR 144.39 or 40 CFR 144.41 (h)

.

• A copy of any requests for additional information or related communications with the owner or operator, including:

o The date of the request.

o The n ames and affiliations of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information.Draft UIC Program Class VI Well Recordkeeping, 34 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities 2.3.5 Fin ancial Responsibility Updates and Notifications On an annual basis, the owner or operator must adjust the cost estimate of the required GS activities for inflation [40 CFR 146.85(c)(2)]. Owners or operators must also revise cost estimates as necessary based on any needed amendments to the AoR and Corrective Action Plan, the Injection Well Plugging Plan, the PISC and Site Closure Plan, or the Emergency and Remedial Response Plan [40 CFR 146 .85(c)(3)] and provide notifications of adverse financial conditions [40 CFR 146.85(d)]. More information on financial responsibility updates and notifications is provided in the UIC Program Class VI Well Financial Responsibility Guidance and ass ociated re porting and recordkeeping activities for owners or operators are described in the UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators

. Over th e lifetime of the project, it is the UIC Program Director’s r esponsibility to review and document the updated cost estimate s , verify that they are accurate, and ensure that qualified independent third-party instruments or self insurance are sufficient to cover the estimated costs

. Detailed information on the UIC Pro gram Director ’s evaluation , including a summary of considerations, is given in the UIC Program Class VI Implementation Manual for State Directo rs
. For the purpos e of ensuring complete and consistent compliance and oversight evaluations and supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC Progra m Directors document the following information resulting from their evaluations of financial responsibility information :

• The d ate of receipt for all submittals.

• The reason for the submittal (e.g., to fulfill the annual cost estimate update requirement, in response to changes in a project plan).

• The date of the UIC Program Director’s review of revised cost estimates or financial responsibility instruments and a determination of whether the updated cost estimate is complete and financial responsibility instruments remain adequate

.

• A description of any deficiencies or concerns. Examples of such deficiencies may include, but are not limited to, insufficient documentation of:

o Additional financial responsibility instruments obtained following an increase in the current cost estimate

.
o Specific activities that have been completed to request release from a financial responsibility instrument.

o Methods to complete cost estim ate updates and adjustment for inflation.

• Any documentation releasing the owner or operator from a financial instrument following completion of specific activities

.Draft UIC Program Class VI Well Recordkeeping, 35 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities • Documentation of any requests to adjust a cost estimate

.

• Documentation of any notifications of adverse financial conditions.

• A copy of any requests for additional information or related communications with the owner or operator, including:

o The date of the request.

o The n ames and affiliations of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information. 2.3.6 Emergency and Remedial Response If the owner or operator obtains evidence of any event or circumstance that may cause endangerment to USDWs, he or she must complete the activities specified in the Class VI Rule at 40 CFR 146.94( b). These include immediately ceasing injection, working to identify and characterize any release, notifying the UIC Program Director wi thin 24 hours, and implementing the approved Emergency and Remedial Response Plan. The UIC Program Director may authorize the owner or operator to resume injection prior to remediation if the owner or operator demonstrates that injection will not endanger USDWs [40 CFR 146.94(c)]. Reporting and recordkeeping requirements for owners or operators associated with emergency and remedial response are discussed in the UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators. See Section 2.3.1 for addi tional information on reporting associated with a loss of mechanical integrity. In the event of an emergency, the UIC Program D irector will communicate with the owner or operator to ensure that appropriate response actions are implemented and that USDWs are protected. If applicable, the UIC Program Director will also review the owner or operator’s demonstration that resuming injection prior to remediation will not endanger USDWs. More information on the UIC Program Director’s responsibilities and evaluations is given in the UIC Program Class VI Implementation Manual for State Directors. For the purpose of ensuring complete and consistent compliance and oversight evaluations and supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC Progr am Directors document the following information resulting from their evaluations:

• The d ate and time of receipt o f any emergency notification s from the owner or operator and a brief description of any incident

.

• A record of communications with the owner or operator regarding the incident, including:

o The date of the communication.Draft UIC Program Class VI Well Recordkeeping, 36 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities o The format of the communication (and a copy, if applicable).

o The n ames and affiliations of parties involved in the communication

.

• A d etermination of whether all appropriate activities specified in the Emergency and Remedial Response Plan are conducted.

• Documentation of any impacts on a USDW.

• A decision regarding whether remediation is required and a description of the necessary remedial action(s).

• A d etermination of whether materials received to demonstrate that resuming injection prior to remediation will not endanger USDWs is complete and suf ficient.

• A description of any deficiencies or concerns regarding submitted materials

.

• A determination regarding the resumption of operations and the date that injection resumes.

• A copy of any requests for additional information or related communications w ith the owner or operator, including:

o The date of the request.

o The n ames and affiliations of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversi ght information

. 2.4 Post
- Injection Phase Following cessation of injection, owners or operators will submit various materials , such as an injection well plugging report, PISC monitoring data, a non- endangerment demonstration , and a site closure report . The UIC Program Director will need to evaluate each submittal and document that it is acceptable and/or how deficiencies were addressed. This section describes these post-injection phase activities and summarizes recommended documentation to support compliance and oversight decisions and the process of adaptive rulemaking. 2.4.1 Injection Well Plugging The Class VI Rule , at 40 CFR 146.92, establishes minimum technical crite ria fo r injection well plugging. At least 60 days prior to plugging, the owner or operator must notify the UIC Program Director of intent to plug the well [40 CFR 146.92(c)]. If the original Injection Well Plugging Plan has been revised, the owner or operator must also provide the revised plan at this time

.Draft UIC Program Class VI Well Recordkeeping, 37 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Within 60 days after plugging, the owner or operator must submit a well plugging report [40 CFR 146.92(d)]. A more complete discussion of well plugging requirements and recommendations can be found in the UIC Program Guidance on Class VI Well Plugging, PostInject ion Site Care, and Site Closure. A description of reporting and recordkeeping requirements for owners or operators is provided in the UIC Program Class VI Well Recordkeeping, Reporti ng, and Data Management Guidance for Owners or Operators. Upon receipt of the injection well plugging report, the UIC Program Director is responsible for verifying that all proposed and approved plugging activities have been properly executed. If the plugging activities deviated from the approved Injection Well Plugging Plan , EPA recommends that the UIC Program D irector request additional information from the owner or operator. More details regarding the UIC Program Director’s responsibilities during the w ell p lugging process can be found in the UIC Program Class VI Implementation Manual for State Directors

. UIC P ro gram Directors should document their evaluations in order to ensure compliance with the Class VI R ule and consistency in imple mentation and oversight decisions . EPA recommends that UIC Program Directors document the following for their evaluation s o f injection well plugging:

• The dat e of receipt of the notice of intent to plug the injection well

.

• The date of receipt of the amended Injection Well Plugging Plan, if applicable, and:

o A determination of whether the amended plan is complete and complies with the requirements of the Class VI Rule.

o The result of the evaluation and the date of the determination.

o Documentation of whether a permit modification is required.

• The planned date on which the injection well is to be plugged and whether this will be witnessed by the UIC Program Director.

• A description of any deficiencies or concerns. Examples of such deficiencies may include, but are not limited to, insufficient documentation of:

o Reading final pressure from downhole pressure transducer.

o Removal of well components, injection tubing and obstructions.

o Well flushing

.
o External MIT

.

• For the injection well plugging report:

o The date of receipt of the report.Draft UIC Program Class VI Well Recordkeeping, 38 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities o A d eterminatio n of whether the report is complete and submitted pursuant to the requirements under 40 CFR 146.92(d), and whether the well was tested and plugged in accordance with the Injection Well Plugging Plan

.
o A description of any identified deficiencies in the report.

• I nformation on contractors used by the owner or operator, if applicable and provided.

• Information on contractors used by the UIC Program Director , if applicable.

• A copy of any requests for additional information or related communications with the owner or operator, including:

o The date of the request.

o The n ames and affiliations of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any other compliance or oversight information

. 2.4.2 PISC and Site Closure Following well plugging, owners or operators must carry out PISC monitoring as specified in the PISC and Site Closure Plan and ultimately close the site [40 CFR 146.93]. During the PISC period, the UIC Program Director wi ll receive and review monitoring data submitted by the owner or operator to ensure that the carbon dioxide plume and associated pressure front are behaving as predicted and are not causing endangerment to USDWs. The owner or operator will also continue to conduct AoR reevaluations according to the schedule in the AoR and Corrective Action Plan (see Section 2.3.3 for more information on AoR reevaluation reporting). EP A expects that most reevaluations in the post-injection phase will not result in changes to the AoR delineation or the AoR and Corrective Action Plan. Prior to authorization for site closure, the owner or operator must submit a demonstration that no additional monitoring is needed to ensure that the project does not pose an endangerment to USDWs [40 CFR 146.93 (b)(3)] . If the demonstration is approved, the site can be closed. Owners or operators must submit a notice of intent for site closure (and a revised PISC and Site Closure Plan, if applicable) at least 120 days before closing the site [40 CFR 146.93(d)]. Following site closure, the owner or operator must submit a report pursuant to [40 CFR 146.93(f)]. At the end of the PISC period, the UIC Program Dire ctor’s responsibilit ies include evaluating the non-endangerment demonstration (including the revised PISC and site closure plan, if applicable) . If the UIC Program Director determines, based on the data presented, that the plume and pressure have stabilized and that the site does not pose a risk to USDWs, he or she may authorize site closure. The UIC Program Director will also need to review documents associated with site closure, including the notice of intent for site closure and site closure report.Draft UIC Program Class VI Well Recordkeeping, 39 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Detailed information on PISC and site closure is provided in the UIC Program Guidance on Class VI Well Plugging, Post-Injection Site Care, and Site Closure. Associated reporting and recordk eeping requirements for owners or operators are described in the UI C Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators. D etailed information on the UIC Program Director ’s evaluation , including a summary of applicable considerations, is given in the UIC Program Class VI Im plementation Manual for State Directors. For the purpos e of ensuring complete and consistent compliance and oversight evaluations and supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC Program Directors document the following information resulting from their evaluations:

• The date of receipt for all submittals.

• For PISC:

o A determination whether the approved PISC and Site Closure Plan needs to be updated and, if so, documentation of the revised plan (e.g., date of submission, any identified deficiencies, result of the UIC Program Director’s determination , the date of the determination ).

o Documentation of the receipt and review of all monitoring data, including the date of the submittal, and whether the results confirm pre dictions about the carbon dioxide plume and pressure front and that no USDW endangerment is indicated.

o A d etermination of whether the submitted documentation is complete and consistent with the requirements under 40 CFR 146.93 and the approved PISC and Site Closure Plan.

o A description of any deficiencies or concerns. These deficiencies may include missing information , insufficiently documented procedures, or the results of specific monitoring activities.

o A determination of whether a revision to the PISC monitoring is needed (e.g., if monitoring results indicate at any point during PISC that the position of the carbon dioxide plume and/or the associated pressure front are different than what was predicted by modeling and described in the approved PISC and Site Closure Plan ).

o Any additional compliance or oversight information.

• For the non-endangerment demonstration:

o The date of submission.

o A d etermination of whether the submitted documentation is complete and complies with the requirements under 40 CFR 14 6. 93.Draft UIC Program Class VI Well Recordkeeping, 40 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities o A description of any deficiencies or concerns. These deficiencies may include missing information, insufficiently documented procedures, poor agreement between monitoring data and model predictions, or a trend of increasing total dissolved solids ( TD S) or other constituents in overlying formations or USDWs.

o An indication of whether site closure is authorized or further PISC is needed, and the date of this determination

.

• For site closure:

o Date of submission of the notice of intent for site closure.

o The planned date(s) of site closure- related activities (e.g., monitoring well plugging) and whether any will be witnessed by the UIC Program Director.

o Date of submission of site closure report, and:

 A d etermination of whether the submitted documentation is co mplete and compliant with the requirements under 40 CFR 146.93(f).

 A description of any deficiencies or concerns , such as insufficient documentation of the plugging of monitoring wells or notifications to applicable parties.

• Documentation that the owner or operator has properly filed survey plats and facility property deed notations and that state, local and t ribal authorities that have authority over drilling activities have been notified.

• I nformation on contractors used by the owner or operator , if applicable and provided.

• Information on contractors used by the UIC Program Director , if applicable.

• A copy of any requests for additional information or related communications with the owner or operator, including:

o The date of the request.

o The names and a ffiliations of parties involved in the communication

.
o Documentation of resolution of issues raised in the request for additional information.

• Any additional compliance or oversight information. 2.4.3 Emergency and Remedial Response As with the injection phase, the owner or operator must carry out emergency notification and remedial response activities if there is evidence of endangerment to USDWs [40 CFR 146.94(b)]. While the requirement to cease injection does not apply to the post-injection phase,Draft UIC Program Class VI Well Recordkeeping, 41 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities the owner or operator must still work to identify and characterize any release, notify the UIC Program Director within 24 hours, and implement the approved Emergency and Remedial Response Plan. Emergency and remedial response r eporting and recordkeeping for owners or operators is discussed in the UIC Program Class VI Well Recordkeeping, Reporting, and Data Management Guidance for Owners or Operators. In the eve nt of an emergency, the UIC Program Director will communicate with the owner or operator to ensure that approp riate response actions are implemented and that USDWs are protected. More information on the UIC Program Director’s responsibilities and evaluations is given in the UIC Program Class VI Well Implementation Manual for State Directors. For the purpos e of ens uring complete and consistent compliance and oversight evaluations and supporting the adaptive rulemaking approach for the Class VI Rule, EPA recommends that UIC Progra m Directors document the information listed in Section 2.3.6 (with t he exception of information related to determining whether injection may resume before remediation, which would not apply in the post-injection phase).

2.5 UIC Program Director Program Rep orting to EPA In addition to reviewing data submitted by owners or operators, UIC Program Directors also report to EPA on the status of their programs. This section discuss es the type of information that is submitted to EPA by UIC Program Directors to resp ond to information requests and perform analyses for EPA management, the Office of Management and Budget (OMB), the U.S

. Government Accountability Office (GAO), Congress , and the public. EPA oversees primacy programs by using submitted reports to track, evaluate, and report on program performance. For the purposes of national program oversight, the UIC Program Director is required to prepare quarterly and annual reports associated with noncompliance to submit to the EPA Regional Administrator in cases wh ere a State Director is the permitting authority or to EPA Headquarters in cases where EPA is the permitting authority [40 CFR 144.8]. Quarterly reporting is required for compliance evaluation and significant noncompliance. Quarterly reporting includes a list of noncomplying permittees ’ name s, location s, and permit numbers and information on violations, enforcement actions, and the number of wells returned to compliance , as required under 40 CFR 144.8, as well as the following , for each entry:

• A brief desc ription and date of each instance of noncompliance. Instances of noncompliance to be reported under 40 CFR 144.8(a)(2) are:

o Failure to complete construction elements.

o Modifications to schedules of compliance.

o Failure to complete or provide compliance schedule or monitoring reports.

o Deficient reports.Draft UIC Program Class VI Well Recordkeeping, 42 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities o Noncompliance with other permit requirements.

o All other instance s of noncompliance.

• The date(s) and description(s) of each enforcement action taken by the UIC Program Director.

• The date compliance was achieved

. All quarterly reports are submitted within the federal fiscal year and must be made available to the public on the date of submission [40 CFR 144.8(c)]. Annual reporting is required for permit review and issuance, mechanical integrity testing and remedial actions, and well inventory. Annual well inventory reports are submitted in February; all remaining annual reports are submitted at the end of the federal fiscal year. Additionally, for Class VI operations, EPA may track the foll owing types of information on injection wells:

• Infor mation on permit determinations ( e.g ., the number of permits issued and not issued, permit modifications) and permit file reviews

.

• Enforcement actions, including administrative actions and civil and criminal actions.

• Operators of injection wells identified as being in significant noncompliance (SNC) with statutory and regulatory requirements , enforcement actions against SNCs , and returns of wells to compliance; contamination of USDWs; and closures

.

• Wells that have rema ined in SNC for two or more consecutive quarters and have not been returned to compliance or been subject to a formal enforcement action. In addition, EPA’s 2011–2015 Strategic Plan contains the following key Strategic Target : “By 2015, 90 percent of commu nity water systems will provide drinking water that meets all applicable health -based drinking water standards through approaches including effective treatment and source water protection.” 4 EPA developed Program Activity Measures (PAMs) to assess progress toward the strategic goal, including two that are specific to Class VI wells:

• Volume of carbon dioxide sequestered through injection as defined by the Class VI R ule.

• Numbe r of permit decisions during the reporting period that result in carbon dioxide sequ estered through injection as defined by the Class VI Rule.

4 U.S. EPA. 2010. Fiscal Year 2011

– 2015 EPA Strategic Plan: Achieving O ur Vision. Available online at: http://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=P1008YOS.txt

.Draft UIC Program Class VI Well Recordkeeping, 43 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Permitting authorities will compile information to respond to mid

- year and end -of- year requests from EPA Headquarters for PAMs data.

2.6 Recordkeeping by the UIC Program Director The only recordkeeping requirement specific to UIC Program Directors in the Class VI Rule pertai ns to PISC monitoring records. Following retention of PISC records for 10 years following site closure , owners or operators must, pursuant to 40 CFR 146.93(h), deliver these records to the UIC Program Director. The UIC Program Director must then designate a location for these records to be retained thereafter. EPA re commends that the UIC Program Director retain all records outside of the electronic data system for the lifetime of the Class VI project.Draft UIC Program Class VI Well Recordkeeping, 44 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities 

## 3 GS Data Submission and Management
Note: At the time this draft document was published, the central data system for Class VI data was under de velopment. To avoid publishing incomplete information, this draft contains a placeholder for the description of GS data management through the use of the central data system

.Draft UIC Program Class VI Well Recordkeeping, A-1 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities 

## Appendix A. Draft Class VI Oversight and Compliance Data Elements Matrix
Table A -1 lists oversight and compliance data elements associated with th e Class VI rule requirements for each GS project phase , along with potential values or types of submittals for each data element . The table is organized according to the content of the Class VI Rule Sub part H requirements, beginning with the permit application submissions

. Table A -1 . Class VI Rule oversight and compliance data elements matrix (DRAFT). Compliance/Oversight Data Element Notes/Potential Values
PRE - INJECTION PHASE Prior to the issuance of a permit for the construction or conversion of a new Class VI well or the conversion of a Class I, Class II, or Class V well to a Class VI well Permit/Facility Information Date; Permit information may also include UIC Database element Ownership_Type (Type of ownership for a UIC well) Permit Application submission date
Permitting Authority/Permit Agency Specific Primacy state or DI program Permit Number Na me of the project that the permit is submitted for Project Name Planned duration of project
Perm it Applicant Project ContactDraft UIC Program Class VI Well Recordkeeping, A-2 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values Facility Information (§146.82(a)(1)) (1) The permitted activities (2) Name, mailing address, and location of the facility (3) Up to four Standard Industrial Classification (SIC) codes (4) The operator’s name, address, telephone number, ownership status, and status as federal, state, private, public, or other entity (5) Whether the facility is located on Indian lands (6) A listing of all permits or construction approvals: Authorization status, Permit action type, and Permit action date F acility information may also include UIC Database elements of: Facility ID, Facility

- State, Facility

- City, Facility

Zip, Facility

- Street, Facility

- Type, NAICS

- Code, Petition

- Status, SIC

- Code

Facility Type Injection well location Latitude and longitude List of contacts for those states, tribes, and territories within the AoR submitted? Complete? Yes, No Complete, non

- complete

Permit application complete? Yes, No Alternatively, a set of permitting milestones might be tracked:
• Date UIC permit scheduled to be submitted
• Draft UIC permit issued
• Public comment period begins
• Method of public notification
• Public hearing
• Public comment period closes
• Region/state sends comments to applicant on official permit application (if needed)
• Region/state receives revi sed permit application (if needed)

• Final UIC permit issued Permit Writer Name of the personDraft UIC Program Class VI Well Recordkeeping, A-3 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values The UIC Program Director’s Public Notice of Draft Permit A PDF copy of the notice Any other information requested by the UIC Program Director Yes, No Type of additional information requested Are injection zone(s) of sufficient areal extent, thickness, porosity, and permeability to receive the total anticipated volume of carbon dioxide stream? Yes, No

NOTE: These may need to be separated into more specific elements to e nsure that §146.83 is satisfied Are confining zone(s) free of transmissive faults or fractures and of sufficient areal extent and integrity to contain the injected carbon dioxide stream and displaced formation fluids and allow injection at proposed maximum pressures and volumes without initiating or propagating fractures in the confining zone(s)? Yes, No

The UIC Program Director requires owner or operator to identify and characterize additional zones that will impede vertical fluid movement, are free of faults and fractures that may interfere with containment, allow for pressure dissipation, and provide additional opportunities for monitoring, mitigation, and remediation? Yes, No

Permit Application Status Construction authorized, Construction not authorized Site Characterization Information

Submitted Information on geologic structure and hydrogeologic properties of storage site and overlying formations (§146.82(a)(3)) Complete, non

- complete Injection zone(s) Injection formation name Confining zone(s) Confining formation names
Fracture pressure(s) (for a given location/formation) This is used to oversee the requirement of injection pressure does not exceed 90% of this value Identified fracture(s); location(s); orientation(s) Complete, non

- complete Identified fault(s); location(s); orientation(s) Complete, non

- complete Geomechanical information Complete, non

- completeDraft UIC Program Class VI Well Recordkeeping, A-4 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values Seismic history information Complete, non - complete Maps and cross

- sections Complete, non

- complete AoR Delineation and Corrective Action Information

A map showing the injection well for which the permit is sought and the applicable AoR consistent with §146.84 (§146.82(a)(2))

• Number, name and location of all injection wells, producing wells, abandoned wells, plugged wells, or dry holes, deep stratigraphic boreholes.
• State or EPA approved subsurface cleanup sites
• Surface bodies of water, springs
• Surface and subsurface mines, quarries
• Water w ells
• Other pertinent surface features (e.g. roads, etc.)
• Faults known or suspected Complete, non

- complete

Simulator/code used for the computational modeling Code name Identified penetrations into the injection zone(s) and confining zone(s) List of penetrations A tabulation of all wells within AoR (§146.82(a)(4)) (well type, construction, date drilled, location, depth, record of plugging) Complete, non

- complete

Wells requiring corrective action Total number, each well identification/location UIC Da tabase also include AoR_Well (number of wells identified in AoR requiring corrective action) NOTE: Data system may need to track the status of each well needing corrective action Maps and stratigraphic cross sections of all USDWs, water wells and springs within the AoR (§146.82(a)(5)) Complete, non

- complete
Phased corrective action proposed/authorized? Yes, No; Authorized, not authorizedDraft UIC Program Class VI Well Recordkeeping, A-5 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values The minimum fixed frequency to reevaluate AoR (proposed in the AoR and Corrective Action Plan) submitted? Sufficient frequency? Yes, No Yes, No Baseline Data

Submitted baseline geochemical data on subsurface formations, including all USDWs in AoR (§146.82(a)(6)) Complete, non

- complete

Submitted surface air and/or soil gas baseline concentrations (if required by the UIC Program Director) Complete, non

- complete NOTE: The data element tracking if this monitoring required is listed under the testing and monitoring section Proposed Operating Data

Average and maximum daily injection rate and volume and/or mass and total anticipated volume and/or mass of carbon dioxide stream total volume submitted? Yes, No NOTE: These are not compliance elements in and of themselves; however , actual operating values will need to be consistent with the values in the final permit Average and maximum daily injection volume and/or mass submitted? Yes, No Total anticipated volume and/or mass of carbon dioxide stream submitted? Yes, No Is the submitted injection rate and volume information consistent with the AoR delineation modeling? Yes, No Average maximum injection pressure submitted? Yes, No Source(s) of the carbon dioxide stream submitted? Yes, No Analysis of chemical and physical characteristics of the stream submitted? Yes, No Financial Responsibility Information

Financial responsibility demonstration Complete, non

- complete

Financial responsibility establishment date Date of the establishment of the financial instrument(s) This information will be used for submitting annual updates Financial responsibility sufficiently covers total costs estimated for all required phases? Yes, NoDraft UIC Program Class VI Well Recordkeeping, A-6 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values Financial responsibility instruments Instruments (Trust Fund, Surety Bond, Letter of Credit, Insurance, Escrow Account, Other) Financial responsibility institutions Institution names

Financial responsibility cost estimates Cost values NOTE: This information may be tracked for each phases, so they can be “removed” as completed. Proposed Programs/Procedures

Pre

- operational testing program submitted? Yes, No Pre

- operational testing program consistent with the requirements under §146.87 Yes, No Stimulation program submitted? Yes, No Stimulation program includes a description of fluids to be used? Yes, No Stimulation program includes a determination that stimulation will not interfere with containment? Yes, No Complete, non

- complete Procedure to conduct injection operation submitted? Yes, No Proposed Plans

AoR and Corrective Action Plan submitted? AoR and Corrective Action Plan complete? AoR and Corrective Action Plan Satisfies the requirements under §146.84? Yes, No Complete, non

- complete Yes, No Testing and Monitoring Plan submitted? Testing and Monitoring Plan complete? Testing and Monitoring Plan Satisfies the requirements under §146.90? Yes, No Complete, non

- complete Yes, No Injection Well Plugging Plan submitted? Injection Well Plugging Plan complete? Injection Well Plugging Plan Satisfies the requirements under §146.92? Yes, No Complete, non - complete Yes, NoDraft UIC Program Class VI Well Recordkeeping, A-7 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values PISC and Site Closure Plan submitted? PISC and Site Closure Plan complete? PISC and Site Closure Plan Satisfies the requirements under §146.93? Yes, No Complete, non

- complete Yes, No Emergency and Remedial Response Plan submitted? Emergency and Remedial Response Plan complete? Emergency and Remedial Response Plan Satisfies the requirements under §146.94? Yes, No Complete, non

- complete Yes, No Injection Well Information

Construction schematics and drawings submitted? Yes, No Construction procedures submitted? Construction procedures complete? Construction procedures satisfies the requirements under §146.86? Yes, No Complete, non

- complete Yes, No Alternative PISC Timeframe Information

Alternative post

- injection site care timeframe demonstration submitted? Complete? Satisfies the requirements under §146.93? Yes, No Complete, non

- complete Yes, No Alternative PISC timeframe? Alternative PISC timeframe consistent with PISC and Site Closure Plan? Alternative PISC timeframe co nsistent with AoR delineation modeling? Alternative PISC timeframe approved? Timeframe Yes, No Yes, No Yes, No Injection Depth Waiver Information Injection Depth Waiver request submitted? Yes, No

Date that injection depth waiver request submitted? Date NOTE: Concurrency with the permit application could be checked from dates of permit application and waiver application automatically Injection Depth Waiver Report complete? Injection Depth Waiver Report satisfies the requirements under §146.95? Complete, non

- complete Yes, NoDraft UIC Program Class VI Well Recordkeeping, A-8 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values Request for additional information OR revised Injection Depth Waiver Report Date of additional information request or request of revision? Yes, No Date The UIC Program Director’s Public Notice that a waiver application has been submitted A PDF copy of the notice
Consultation with PWSS Directors? Information about the waiver forwarded to EPA Regional Administrator (RA)? Concurrence or non

- concurrence sent by the RA to the UIC Program Director Yes, No; Date; A PDF copy of the written document; PDF copies of any responses Yes, No; Date A PDF of copy of decision
Injection Depth Waiver Issued? Issued, not issued If ”Not issued”, select another site or formation, restart permit application The UIC Program Director’s notification to states, tribes, or territories within the AoR based on §146.82(a)(2) and (19) of the permit application and pursuant to §145.23(f)(13) A PDF copy of the notification sent to contacts in the list provided by o/o Information necessary prior to UIC Program Director’s approval for operation of a Class VI well Well construction scheduled to begin? Date NOTE: This information may be captured in proposed well construction procedures submitted with the permit application Well construction or well reworking commences (if applicable) Date Well construction or well reworking complete (if appropriate) Date

Final AoR submitted? Complete? Satisfies the requirements under §146.84? Yes, No Complete, non

- complete Yes, No Updates to the geologic structure and hydrogeologic properties of the site submitted? Complete? Yes, No Complete, non

- complete Information on the compatibility of the stream submitted? Complete? Yes, No Complete, non

- complete Is the stream compatible with fluids in the injection zone(s) and minerals in both the injection and the confining zone(s) based on the results of the formation testing program? Yes, No Is the stream compatible with the materials used to construct the injection well? Yes, NoDraft UIC Program Class VI Well Recordkeeping, A-9 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values

The results of the formation testing program submitted? Complete? Satisfies the requirements under §146.87? Yes, No Complete, non complete Yes, No NOTE: This information may need to be tracked test by test; f or each test, tracked information could include the test, date, and result for a list of tests (e.g., deviation checks, logs) All logging/testing program data on the well submitted? Yes, No Final injection well construction procedures submitted? Complete? Satisfies the requirements under §146.86? Yes, No Complete, non

- complete Yes, No Status of corrective action for identified wells? Complete, initial phase complete, non

- complete Mechanical integrity (MI) demonstration submitted? Yes, No MI test date(s) Date conducted MI test(s) MIT results [pass/fail] Any tests witnessed by UIC Program inspectors? Yes/no; tests; date; inspector Specific tests used Pass, Fail Yes, No; Tests, Dates; Inspector Name, affiliation Any updates to proposed AoR and Corrective Action Plan submitted? Yes, No Any updates to proposed Testing and Monitoring Plan submitted? Yes, No Any updates to proposed Injection Well Plugging Plan submitted? Yes, No Any updates to proposed Post

- Injection Site Care and Site Closure Plan submitted? Yes, No Any updates to proposed Emergency and Remedial Response Plan submitted? Yes, No Any updates to financial responsibility demonstration submitted? Yes, No Any updates to injection depth waiver information submitted? Yes, No Any updates to proposed Alternative post

- injection site care timeframe demonstration submitted? Yes, NoDraft UIC Program Class VI Well Recordkeeping, A- 10 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values

Director approval for injection Injection authorized, non

- authorized INJECTION PHASE Injection well operati on

The date injection commenced? Initial date of injection activity

Injection pressure within permitted levels? Yes, No Values recorded with continuous recording devices are compared against the values in the permit application and the fracture pressure. If “No”, see emergency and violations Injection between the casing and well bore? Yes, No If “No”, see emergency and vi olations Is the non

- corrosive fluid used to fill the annulus between tubing and long string casing approved by the UIC Program Director? Yes, No Does the UIC Program Director approve the annulus pressure less than the operating pressure? Yes, No

Does the annulus pressure exceed the operating pressure? Yes, No If last two answers are “No”, see emergency and violations Are continuous recording devices installed and used for: o Injection pressure o Injection rate o Volume/mass o Temperature of the stream o The pressure on the annulus o Annulus fluid volume Yes, No If “No”, see violations

Continuous recording device description(s) Specific device brand, model, etc. Are alarms and automatic shut

- off systems installed and used? Yes, NoDraft UIC Program Class VI Well Recordkeeping, A- 11 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values Does the UIC Program Director approves down

- hole shut

- off systems (for onshore wells), or other mechanical devices that provide equivalent protection? Yes, No
Automatic shut

- off system description(s) Specific device brand, model, etc. Are alarms and automatic down

- hole shut

- off systems installed and used for off

- shore wells? Yes, No Automatic down

- hole shut

- off system description(s) Specific device brand, model, etc. Mechanical Integrity

Scheduled date of MIT NOTE: This information could be directly pulled out from the permit and compared against the MIT date below
MI failure Yes, No If “Yes”, see emergency and violations MIT date Date conducted

Previous MIT date Date conducted previously if MIT date

- Previous MIT date < 1 year, see emergency and violations Test(s) conducted Alternate test conducted? Yes, No NOTE: Alternate methods are more likely to be determined during the permit application in the Testing and Monitoring Plan; h owever, there might be a need to adopt new met hods during operation as well A written request submitted by the UIC Program Director to the RA setting forth the proposed alternate test and all technical data submitted Yes, No The RA approval for the alternate test? Yes, No The alternate method published in the Federal Register Yes, No

Results of MIT submitted? Yes, No Date if Results submitted > 30 days of MIT date, see violationsDraft UIC Program Class VI Well Recordkeeping, A- 12 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values

Date Results of MIT submitted? Date if Results submitted > 30 days of MIT date, see violations Casing inspection log required? Yes, No Scheduled date for conducting casing inspection log From permit
Date casing inspection log conducted Date conducted if Results submitted after due date, see violations Previous casing inspection log date This must be consistent with the frequency approved in the Testing and Monitoring Plan Results of casing inspection log submitted? Yes, No
Date Results of casing inspection log submitted? Date if Results submitted > 30 days of date conducted, see violations Testing and Monitoring Date analysis is due? Date Injectate ( carbon dioxide stream) analysis submitted Date Date submitted If no date or after due date, see violations Data sufficient for the chemical and physical characteristics? Yes, No Yes, No
Injectate analysis parameters (measured for analyzing the stream)? Consistent with the Testing and Monitoring Plan? pH, carbon dioxide concentrations, other constituents Yes, No If “No”, see plan updates Injectate sampling method(s) May be needed to assess the consistency if there is any change Injectate analysis method(s) May be needed to assess the consistency if there is any changeDraft UIC Program Class VI Well Recordkeeping, A- 13 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values Date injectate sample is taken Date of sampling for each sample Date injectate analysis conducted Date of actual lab analysis for each sample Laboratory conducting the injectate analysis Laboratory name, location, contact information Results of injectate analysis submitted (if there are any changes to the physical, chemical, and other relevant characteristics of the injectate from the proposed operating data) with the semi

- annual reports? Yes, No If “No”, see violations Are the following continuously monitored: o Injection pressure o Injection rate o Volume/mass o Temperature of the stream o The pressure on the annulus o Annulus fluid volume Yes, No

Reporting period? Beginning date, ending date Are recorded values consistent with the permitted values? Yes, No If “No”, see emergency and violations Results submitted in the semi

- annual reports as: o Monthly average, maximum and minimum values for injection pressure, flow rate, volume, and

annular pressure o A description of any event exceeds operating parameters for annulus pressure or injection

pressure specified in the permit o Monthly volume and/or mass of the injectate injected over the reporting period and volume

injected cumulatively over the life of the project Yes, No

Results submitted complete? Yes, No If “No”, see violations Scheduled dates Corrosion monitoring (required quarterly) Date
Corrosion monitoring method? Testing method (coupons, loop, alternate method)Draft UIC Program Class VI Well Recordkeeping, A- 14 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values Date corrosion testing conducted Date of the actual testing Alternate corrosion monitoring method approved by the UIC Program Director? None, method Corrosion signs observed? Yes, No If “Yes”, see violations Type of corrosion signs observed? None, loss of mass, loss of thickness, cracking, pitting, and other Results of corrosion monitoring submitted in the semi

- annual report? Yes, No If “No”, see violations Groundwater quality and geochemical changes monitored periodically? Yes, No Method(s) of sampling Direct sampling, etc. Date(s) of sampling conducted for each measurement? Date of actual sample retrieval Date(s) of sample analysis Date of actual lab analysis Laboratory conducting the analyses Laboratory name, location, contact information Location and depth of each sample taken? Monitoring well location, depth Measured/monitored parameters? pH, temperature, concentration of carbon dioxide , concentrations of metals, etc.
Results submitted in the semi

- annual report Yes, No If “No”, see violations Any significant groundwater quality or geochemical changes observed? Yes, No If “Yes” see emergency and violations Location/time of any significant groundwater quality or geochemical changes observed compared to the baseline data submitted in the permit application? Monitoring well, depth
Pressure fall

- off test conducted (at least once every five years or consistent with the frequency information approved in the Testing an d Monitoring Plan) Yes, No
Estimated formation characteristics Transmissivity, othersDraft UIC Program Class VI Well Recordkeeping, A- 15 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values Date the pressure fall

- off test conducted Date
Results submitted in the semi

- annual report? Yes, No If “No”, see violations Any significant changes in values estimated previously and used in computational modeling Yes, No If “Yes”, AoR reevaluation may be needed Pressure front and plume tracking conducted? Yes, No If “No”, see violations Date(s) and location of monitoring of pressure front conducted? Dates and location Date(s) and location of monitoring of plume conducted? Dates and location Method(s) of pressure front monitoring? Specific methods used for each monitoring activity Method(s) of plume monitoring? Specific methods used for each monitoring activity
Results submitted in the semi

- annual reports? Yes, No If “No”, see violations Any significant difference between actual and predicted pressure front and plume? Yes, No If “Yes”, AoR reevaluation may be needed
Does Director require surface air and/or soil gas monitoring? Yes, No If “No”, rest of the elements related to surface air and/or soil gas monitoring will not be filled. Surface air and / or soil gas monitoring method(s) Specific methods used Surface air and / or soil gas monitoring location(s) Specific location where testing is conducted Surface air and / or soil gas monitoring date(s) Actual testing dates Surface air and / or soil gas monitoring parameter(s) carbon dioxide concentrations, other Laboratory conducting the analyses (if applicable) Laboratory name, location, contact informationDraft UIC Program Class VI Well Recordkeeping, A- 16 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values
Results submitted in the semi

- annual reports? Yes, No If “No”, see violations Any significant results indicating release into atmosphere or biosphere (in comparison to the baseline information submitted in the permit application)? Yes, No If “Yes”, see emergency and violations Any additional monitoring required by the UIC Program Director (to support computational modeling)? Yes, No Type of monitoring required? Scheduled date for required monitoring Date Location of monitoring? Results submitted in the semi

- annual reports or within 30 days of conducting any test of the injection well? Yes, No
Any significant results indicating an emergency type? Yes, No If “Yes”, see emergency Quality Assurance Surveillance Plan (QASP) submitted? Yes, No If “No”, see violations Emergency/Triggering of a Shut

- Off S ystem Date and time of event Date, time
Notification received within 24

- hour of emergency condition occurring Yes, No If “No”, see violations

Emergency type An endangerment to a USDW, Any non

compliance with permit condition, Any triggering of a shut

- off system, Any failure to maintain MI, Any release to the atmosphere or biosphere Injection ceased? Yes, No If “No”, see violations Response takenDraft UIC Program Class VI Well Recordkeeping, A- 17 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values Leakage occurred/suspected? Yes, No A description submitted in the semi

- annual report of any event which triggers a shut

- off device Yes, No If “No”, see violations Violations Facility ID Permit ID Permitting authority contact Violation description MIT failure, Recordkeeping violation, etc. (as listed on 7520 forms) Violation reported by Owner or Operator, Permitting Authority Date violation occurred Date violation reported Date remedial action reported Date remedial action occurred Remedial action conducted by Remedial action reported by Verifying action MIT, measured values, etc. Verification date Notification to the UIC Program Director with the date that injection can resume submitted? Yes, No The UIC Program Director approves the date the injection can resume? Yes, No AoR Reevaluations and Corrective Action (Additional or Phased) Scheduled date of AoR reevaluations (as specified in the permit) Date Additional corrective action need? Yes, NoDraft UIC Program Class VI Well Recordkeeping, A- 18 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values List of wells that need corrective action not identified in the permit Well IDs, locations, etc. Corrective action conducted according to the phased corrective action plan approved with the permit? Yes, No If “No”, see emergency and violations List of wells t hat received corrective action based on the phased corrective action plan Well IDs, locations, etc.
Date AoR reevaluation submitted? Date If date after scheduled date, see violations
Was reevaluation scheduled? Yes, No If “No”, what was trigger? Demonstration of no amendment need submitted? Yes, No An amendment to the AoR and Corrective Action Plan submitted? Yes, No The UIC Program Director approves the amendment or the demonstration for no amendment need

The approved amendment is incorporated into the permit Yes, No If “Yes”, other plans and financial responsibility need to be reviewed NOTE: A “Permit versioning” data element may need to be created for tracking the process for each modification: draft per mit, date of public notice, final permit Other Plan Updates Date demonstration of no amendment need for the reviewed Testing and Monitoring P lan submitted? Date Date amendment to the reviewed Testing and Monitoring P lan submitted? Date Date Director approves the amended Testing and Monitoring P lan or the demonstration for no amendment need Date Date demonstration of no amendment need for the reviewed Emergency and Remedial Response plan submitted? Date
Date amendment to the reviewed Em ergency and Remedial Response P lan submitted? DateDraft UIC Program Class VI Well Recordkeeping, A- 19 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values Date Director approves the amended Emergency and Remedial Response P lan or the demonstration for no amendment need Date Review the Well Plugging Plan Yes, No Review the PISC and Site Closure Plan Yes, No

The approved amendment is incorporated into the permit Yes, No If “Yes”, other plans and financial responsibility need to be reviewed NOTE (same as in previous section ): A “Permit versioning” data element may need to be created for tracking the proce ss for each modification: draft permit, date of public notice, final permit Financial Responsibility Date financial responsibility demonstration update due Date Annual financial responsibility cost estimates submitted (within 60 days prior to the anniversary date of the establishment; within 60 days of any amendments to the plans; and when required by the UIC Program Director)? Date If no date or after due date, see violations
Notification of an adverse financial condition? Yes, No The UIC Program Director approves the cost estimates? Yes, No Adjust the face amount of financial assurance instrument(s) Yes, No The UIC Program Director approves the instrument(s) Yes, No Recordkeeping The UIC Program Director requires a certain submittal to be resubmitted? Yes, No Required information? Specific submittal Required information resubmitted? Yes, No If “No”, see violationsDraft UIC Program Class VI Well Recordkeeping, A- 20 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values
POST
- INJECTION PHASE Injection ceased? Date If “No”, see the “Injection Phase” Date notice of intent to plug submitted (at least 60 days prior to plugging)? Date The Injection Well Plugging Plan submitted with the notice of intent to plug (if any changes have been made to the original Injection W ell P lugging P lan )? Yes, No The UIC Program Director approves a shorter notice period? Yes, No If approved, length of the shorter period? The date the notice of intent to plug is submitted The date the Injection Well Plugging Plan submitted (if revised) The date the injection well plugged Date plugging report submitted (within 60 days after plugging)? Date If > 60 days, see violations PISC and Site Closure Submit an amended PISC and Site Closure Plan, or demonstrate no amendment needed? Amended plan, no amendment demonstration Submitted plan or demonstration approved by the UIC Program Director? Date Monitor the site (at least 50 years, or for the duration of the alternative timeframe approved in the permit) Yes, No Monitoring consistent with the PISC and Site Closure Plan? Yes, No Date and location of monitoring activities submitted Date Results of monitoring activities submitted in semi

- annual reports? Date Any significant results indicating an emergency type? Yes, No If “Yes”, see emergency and violations A non

- endangerment demonstration submitted? DateDraft UIC Program Class VI Well Recordkeeping, A- 21 March 2 013 Reporting , and Data Management Guidance for Permitting Authorities Compliance/Oversight Data Element Notes/Potential Values
The UIC Program Director approves the non

- endangerment demonstration Yes, No If “No”, PISC and Site Closure Plan may need to be amended If non

- endangerment demonstration is not approved, an amendment to the PISC and Site Closure Plan or no amendment needed demonstration submitted? Yes, No If “No”, see violations The UIC Program Director approves the amendment or no amendment needed demonstration Date If non

- endangerment demonstration is approved, a notice of intent for site closure is subm itted (at least 120 days before site closure) Yes, No The UIC Program Director authorizes the site closure? Yes, No
Date of site closure The date for the completion of plugging all monitoring wells, and restoring site A site closure report submitted (within 90 days of site closure) Date If > 90 days , see violations The UIC Program Director approves the site closure report Date A notation on the deed to the facility property is recorded Date If no date, see violations